Privacy Policy

Overview

Quaife.net Limited (“Quaife.net”, “we”, “us” or “our”) is committed to protecting and respecting your privacy.

This policy (together with our Merchant Payment Gateway Terms and Conditions (“Terms and Conditions”) and any other documents referred to in it) sets how we collect and process personal data we collect from you, third parties, or that you provide to us, with respect to the services supplied via this website (www.quaife.net or “our site”), and related to the provision of the Quaife.net Payment Gateway Platform, including, without limitation, Dynamic Currency Conversion and Multi-Currency Processing (collectively referred to as the “Services”). This privacy policy covers personal data that we collect through this website and while providing the Services to our customers (“customer”, “you” or “your”) as a controller of your personal data.

This policy does not cover the personal data that you provide or we collect on your behalf acting as the data processor (mainly in relation to your “Customers” as defined in the Terms and Conditions) for which you remain responsible. We direct you to Section 13 of our Terms and Conditions and in particular sub-sections 13.9 to 13.13 regarding personal data you pass to us or we otherwise collect from you regarding your “Customers”.

Please read the following carefully so that you are fully aware of how and why we are using your personal data.

This policy provides you with the information required by the Regulation (EU) 2016/679 of the European Parliament and Council on the protection of natural persons with regard to the processing of personal data (the General Data Protection Regulation or “GDPR”).

By “personal data”, “data”, and “your information”, as used in this policy, we mean any data about you, which you or third parties provide to us, that is capable of identifying you (whether by itself or when linked with other information in our possession, or likely to come into our possession). This is personal data as defined in the GDPR. Personal data does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with you. We also sometimes refer to “processing”. This means any operation we perform on your personal data, such as collection, organising, storing, updating, using, disclosing and erasing.

Controller

Quaife.net Limited is the controller and responsible for your personal data. We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out in Contact section below.

Information we may collect about you

We may collect and process different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes [first name, last name, job title, username or similar identifier, formal identity document numbers and date of birth (in relation to our customer’s business representatives and other employees, beneficial owners, directors and authorised users, as applicable)].
  • Contact Data includes [address, email address and telephone numbers].
  • Financial Data includes [bank account details and payment card details (such as those provided to carry out test transactions)].
  • Transaction Data includes [details about payments to and from you and other details of products or services you have purchased from us].
  • Technical Data includes [internet protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting and location, browser plug-in types and version, operating system and platform, and other technology on the devices you use to access this website or use our Services].
  • Profile Data includes [your username and password, your interests, preferences, feedback and survey responses].
  • Usage Data includes [information about how you use our website, products and services, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products/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 page and any phone number used to call our customer service number].
  • Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
  • We also record all telephone conversations with customers
  • Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, foreign exchange and payment service providers, business partners, referral agents, sub-contractors in technical services, advertising networks, analytics providers, search information providers, credit reference agencies and fraud prevention agencies or other similar organisations – who may check the information against any particulars on the Electoral Register and any other databases) and may receive information about you from them.

How is your personal data collected?

We may collect data from and about you from different sources:

We use information held about you in the following ways:

    • Information you give us. You may give us information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you request information on our site and/or our Services, when registering for our Services and when you report a problem with our site or one of our Services. Such information may include but not be limited to business information (name, registration details, address), contact details of the business’ representatives, directors and other employees or beneficial owners’ and authorised user’s details (such as name and address, date of birth and formal identity document numbers), banking details, purpose of the business, and annual revenue or other financial information. When you visit our site, you have the ability to conduct a limited number of live “test” transactions and experience our Services without formally contracting for them. To monitor these test transactions, we collect technical information such as is listed in the bullet point below, plus any personal data and credit card information that you provide to conduct the test transactions.
    • Information we collect about you:
      • Information about you where you are our Customers’ business representative, directors, other employees, beneficial owner or authorised users as set out above can be provided to us by or on behalf of our Customer when registering for our Services on the website and in other circumstances described above.
      • With regard to each of your visits to our site we may automatically collect the following information:
        • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
        • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products/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 page and any phone number used to call our customer service number.
        • We also record all telephone conversations with customers
      • Information we receive from other sources.
        • We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.
        • We are also working closely with third parties (including, for example, foreign exchange and payment service providers, business partners, referral agents, sub-contractors in technical services, advertising networks, analytics providers, search information providers, credit reference agencies and fraud prevention agencies or other similar organisations – who may check the information against any particulars on the Electoral Register and any other databases) and may receive information about you from them.

Cookies

Cookies are small data files which we place on the browser or hard drive of your/the site user’s computer, as an identifier, if you agree. Each time your computer/browser is used to visit our site, cookies enable us to recognise you as a returning customer and track your use of our site. Such cookie use is for the purposes of system efficiency and minimisation of transaction processing time. Also to prevent un-authorised access to your account online. If you are accessing your account we require cookies to be used to ensure your data is secure. We do not use cookies to track your internet usage after leaving our site and we do not store personal information in them that others could read and understand.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block cookies (including essential cookies) you may not be able to access all or parts of our site.

The table below informs you of the individual cookies we use and the purposes for which we use them:

Purpose/ActivityType of DataLawful basis for processing including basis of legitimate interestMore Information
Quaife.net, Zopim.com, Zopim.io (These URLs will generate session cookies)Session

Cookie each time website is browsed.

These session cookies store data temporarily during the session in which you are browsing our website only and do not retain any data after the browser is closed. Session cookies do not collect information from the user’s computer. They enable us to:

• Store information about your preferences, and so allow us to customise our site. Speed up your searches.

• Allow you to use our site in a way that makes your browsing experience more convenient. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit.

See Cookielaw.org for information about your rights regarding cookies.
Google AnalyticsGenerates statistical and other information about website use and compiles demographic, profile and usage data relating to the site and our Services. The information is used to create reports about the use of the website and our Services.https:// www.google.com/ policies/ privacy/ partners/

Third-party links

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Purposes and legal bases for which we will process your personal data

We have set out below, in a table format, a description of the purposes of our processing of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are processing your data.

Purpose/ActivityType of DataLawful basis for processing including basis of legitimate interest
To register a new Customer(a) Identity
(b) Contact
(c) Financial
Performance of a contract with you or taking steps to enter into such a contract at your request.
To provide you with the information, products and services that you request from or via us, including:

(a) bill and report to you;
(b) managing payments, fees and charges, including Rewards Payments;
(c) collect and recover money owed to us;
(d) assist with customer queries;
(e) manage customer accounts and issue login details.

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
• Performance of a contract with you
• Necessary for our legitimate interests (to recover fees/debts due to us)
To manage our relationship with you which will include:
(a) notifying you about changes to our Service and/or Terms and Conditions and/or privacy policy
(a) Identity
(b) Contact
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertising, to provide you with information about other goods and services we offer that we feel may be of interest to you, to ask you to complete a review or survey or understand the effectiveness of advertising we serve to you.(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Transaction
(f) Marketing and Communications
(g) Technical
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
(b) Consent
To administer and protect our business and our site and for our internal operations (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Change of purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or enrolled for a service with us provided that you have opted-in to receive marketing.

We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes. If we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by emailing us at contact@quaife.net.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at contact@quaife.net. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of subscribing for our Services.

Disclosure of your personal data

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:

        • foreign exchange service providers and payment service providers to facilitate provision of our Services to you;
        • where you were referred to us by a referral agent to whom we pay a referral fee, we may share your Transaction data with such referral agents to enable them to verify the amounts of fees we pay them;
        • business partners, agents, suppliers and subcontractors appointed by us to perform services for us or on our behalf to enable us to provide this website and/or our Services to you;
        • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
        • analytics and search engine providers that assist us in the improvement and optimisation of our site;
        • credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
        • where we have obtained your express opt-in consent, with selected third parties to provide you with information about goods or services we feel may interest you.

We may disclose your personal information to third parties

        • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
        • If Quaife.net Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
        • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of Quaife.net Limited and/or, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Some of IT vendors act as our technology providers based on the software-as-a-service (SAAS) business model. In this case, we use their information systems installed on their hardware environment. Respectively, our databases may be kept on the servers of such vendors. In this case, we limit an access of the IT vendors by the mean of integrated management rules, which prevent a vendor from accessing the data kept by its clients.

International transfer of your personal data

Some of our external third parties may be based outside the European Economic Area (“EEA”), so the data that we collect from you may be transferred to, and stored at, a destination outside the EEA and/or processed by staff operating outside the EEA who work for us or for one of our suppliers.  Except where the transfer is necessary to perform a contract with you or to implement pre-contract measures at your request or to perform or conclude a contract with a third party (including your associated business) in your interest, we will ensure at least one of the following safeguards is implemented:

  • we will only transfer the data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • where we transfer the data to third parties, we will use specific contracts between us and the recipient in a form approved by the European Commission to protect it; or
  • where the recipient is a member of our group, where we have in place binding corporate rules approved, where applicable, by relevant data protection authorities; or
  • where the transfer is to the USA, the recipient is within the EU-US Privacy Shield.

Storage and handling of your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Information about you is predominantly stored on secure computer servers and filing systems. We take reasonable steps and use up-to-date techniques and processes to protect customer information from misuse, loss and unauthorised access, modification and disclosure.

We also maintain up-to-date computer and network security systems with appropriate firewalls, encryption technology and passwords to protect electronic copies of customer information.

We will store your information (with the exception of anonymised transactional data) only for as long as it is reasonably necessary taking into consideration the term of your agreement with us and our need to answer queries, resolve problems, provide improved and new Services and comply with legal requirements under applicable law(s) and those of our suppliers. After this period, we will take reasonable steps to destroy or permanently anonymise customer information which is personal data. [Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request from us by contacting us].

AND/OR
[By law we have to keep basic information about you (including Contact, Identity, Financial and Transaction Data) for [six] years after our business relationship with you for [tax]a purposes.] After this period, we will take reasonable steps to destroy or permanently anonymise customer information which is personal data.

To ensure the security of customer information, we ask that you observe the security requirements that relate to the use of your customer information and account, including log-in details and passwords.

We use leading encryption technologies to secure your data on a hardware and software levels. The hardware protection includes Cisco security products. The software protection tools include strict control mechanisms as follows: SSL 3, TLS 1.2 with keys larger than 2048-bit.

Your provision of Personal Data of others

Where we need you to provide personal data by law, or under the terms of Terms and Conditions or any other contract we have with you or in order to enter into a contract we will inform you. If you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a product or service you have with us or provided by other third parties through us but we will notify you if this is the case at the time.

Where you provide personal data to us relating to other persons (e.g. beneficial owners’ details, business representatives’ details, authorised user details you confirm that you have their consent or are otherwise entitled to provide this information to us and for us to use it in accordance with this agreement.

Your rights

You have the right to:

  • Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us by [INSERT RELEVANT CONTACT DETAILS, e.g. by emailing contact@quiafe.net]].

No fee usually required: you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by emailing us at contact@quaife.net.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Changes to our privacy policy

We keep our privacy policy under regular review. Any changes we may make to our privacy policy in the future will be posted on https://quaife.net/privacy-policy/ and, where appropriate, notified to you by e-mail.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Contact

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Quaife.net Limited

Email address: contact@quaife.net

Postal address: 4 Rockville, Battery Hill, Portreath TR16 4NW

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.