SSV Consumer/Merchant App Privacy Policy

This Privacy Policy sets out how SSV uses and protects your personal data that SSV receives from you when you use SSV’s payment application (the App).  This SSV Consumer/Merchant App Privacy Policy is in addition to the Privacy Policy that applies when you use SSV’s website.

Consent to installation of the App

Under data protection laws, SSV is required to provide you with certain information about SSV, how SSV processes your personal data and for what purposes, and your rights in relation to your personal data. This information is provided below and it is important that you read that information.

Before installation of this App, please indicate your consent to SSV processing your personal data (including your name, contact details, financial and device information) as described in this policy.

YES I consent to the installation of the App for the purposes of making/receiving payments

NO I do not consent to the installation of the App.

How you can withdraw consent

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting SSV at info@ssvsmartpay.co but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Consent to processing Location Data

YES I consent to processing of my Location Data (including details of my current location disclosed by GPS technology so that location-enabled services are activated.

NO I do not consent to processing of my Location Data and location-enabled services are disabled in my settings.

How you can withdraw consent

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting SSV at info@ssvsmartpay.co but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Introduction

This policy (together with the Terms and Conditions as set out at [WEB ADDRESS] and any additional terms of use incorporated by reference into those Terms and Conditions, together the Terms of Use) applies to your use of:

• SSV SmartPay mobile application software (App) hosted on https://ssvsmartpay.azurewebsites.net/ (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App (Services) that are available on the App Site or other SSV sites (Services Sites), unless the Terms of Use state that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies. This policy sets out the basis on which any personal data SSV collects from you, or that you provide to SSV through your interactions with the App will be processed by SSV.

Please read the following carefully to understand SSV’s practices regarding your personal data and how SSV will treat it.

Important information about SSV

SSV is the controller and responsible for your personal data that you disclose to SSV.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact SSV using the information set out in the contact details section.

Personal data means any information about an individual from which that person can be identified.

SSV may collect, use, store and transfer different kinds of personal data about you which SSV has grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes email address and telephone numbers.
• Financial Data includes bank account name and number.
• Transaction Data includes details about payments to and from you and other details of products and services provided SSV that you use.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, Device ID and other technology on the Devices you use to access this App.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  
• Usage Data includes information about how you interact with and use SSV’s products and services.
• Device Data includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.
• Location Data includes your current location disclosed by GPS technology.
• Marketing and Communications Data includes your preferences in receiving marketing from SSV and third parties and your communication preferences.
• Content Data: includes information stored on your Device.
• Usage Data: includes details of your use of any of the App or your visits to any of the Services Sites.

SSV also collects, uses and shares aggregated data such as statistical or demographic data which is not personal data as it does not directly or indirectly reveal your identity. For example, SSV may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with SSV’s website to help improve the website and SSV’s service offering.

How is your personal data collected?

SSV will collect and process the following data about you:

• Information you give SSV. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving SSV about you by filling in forms on the App Site and the Services Sites, or by corresponding with SSV (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any SSV Services, search for an App or Service and when you report a problem with an App, the App Site, the Services or the Services Sites. If you contact SSV, SSV will keep a record of that correspondence.
• Information SSV collect about you and your Device. Each time you visit one of the App Site or Services Sites or use one of the Apps SSV will automatically collect personal data including Device, Content and Usage Data. SSV collects this data using cookies and other similar technologies. Please see SSV cookie policy for further details.
• Location Data. SSV also uses GPS technology to determine your current location. Some of SSV’s location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
• Information SSV receives from other sources including third parties and publicly available sources. SSV will receive personal data about you from various third parties and public sources as set out below:
  • Device Data from the following parties:
    • analytics providers such as Google;
    • advertising networks; and
    • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
  • Identity and Contact Data from data brokers or aggregators;
  • Identity and Contact Data from publicly available sources.

Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to SSV.

Cookies

SSV uses cookies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps SSV to provide you with a good experience when you use the App or browse the Services Sites and also allows SSV to improve the App and the Services Sites. For detailed information on the cookies SSV uses, the purposes for which SSV uses them and how you can exercise your choices regarding SSV’s use of your cookies, see SSV’s cookie policy https://ssvsmartpay.azurewebsites.net/legal/SSV-Privacy-and-Cookies-Policy

How SSV uses your personal data

SSV will only use your personal data when the law allows it to do so. Most commonly SSV will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where it needs to perform a contract it is about to enter or has entered with you.
• Where it is necessary for SSV’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where SSV needs to comply with a legal or regulatory obligation.

Purposes for which SSV will use your personal data

Direct marketing

During the registration process when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from SSV via email, text, telephone or post.

SSV may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that SSV can then send you relevant marketing communications.

Third-party marketing

SSV will get your express consent before SSV shares your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask SSV to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting SSV at info@ssvsmartpay.co.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example checking that your contact details are correct.

Disclosures of your personal data

When you consent to providing SSV with your personal data, SSV will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table:

• Business partners, such as Yapily Connect Ltd, for the purpose of fulfilling and administering the contract SSV enters into with you
• Other users of the SSV Services
• Merchants – in order for payments to be made to merchants and refunds to be made by merchants
• Promotional events and marketing organisations – subject to the above in relation to your marketing preferences
• Regulators and law enforcement authorities – where SSV is under a duty to disclose or share your personal data in order to comply with a legal obligation, prevent fraud or in order to enforce or apply its terms of use and other agreements; or to protect the rights, property, or safety of its clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection
• Third parties to whom SSV may choose to sell, transfer or merge parts of its business or assets. Alternatively, SSV may seek to acquire other businesses or merge with them. If a change happens to SSV’s business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Automated Decision-Making and Profiling

If SSV uses personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions, requesting human intervention, expressing their own point of view, and obtaining an explanation of SSV’s decision.

SSV make automated decisions to determine whether to allow a transaction or not based on the checks carried out through SSV’s transaction monitoring service which monitors suspicious transactions based on factors such as:

• the age of merchant;
• size of transaction;
• time of day; and
• type of transaction - customer present or not present.

Depending upon the results of the checks carried out, this could result in SSV automatically declining a transaction. The right to object to automatic processing of your personal data does not apply in the following circumstances:

• the decision is necessary for the entry into, or performance of, a contract between the you and SS;
• the decision is authorized by law; or
• you have given you explicit consent.

International transfers

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

Whenever SSV transfers your personal data out of the UK to service providers, it ensures a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• SSV will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data;
• SSV may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, 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 SSV at info@ssvsmartpay.co

Data security

All information you provide to SSV is stored on SSV’s secure servers. Where SSV has given you (or where you have chosen) a password that enables you to access certain parts of the Services Sites, you are responsible for keeping this password confidential. SSV asks you not to share a password with anyone.

SSV will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

SSV has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, SSV limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on SSV’s instructions and they are subject to a duty of confidentiality.

SSV put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where SSV is legally required to do so.

Data retention

SSV will only retain your personal data for as long as reasonably necessary to fulfil the purposes SSV collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. SSV may retain your personal data for a longer period in the event of a complaint or if it reasonably believe there is a prospect of litigation in respect to its relationship with you.

To determine the appropriate retention period for personal data, SSV considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which it processes your personal data and whether it can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask SSV to delete your data as set out below.

In some circumstances SSV will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case SSV may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 180 days then SSV will treat the account as expired and your personal data may be deleted.

Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

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 SSV holds about you and to check that SSV is lawfully processing it.
• request correction of the personal data that SSV holds about you. This enables you to have any incomplete or inaccurate data SSV holds about you corrected, though SSV may need to verify the accuracy of the new data you provide to SSV.
• request erasure of your personal data in certain circumstances. This enables you to ask SSV to delete or remove personal data where there is no good reason for SSV continuing to process it. You also have the right to ask SSV to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where SSV may have processed your information unlawfully or where SSV is required to erase your personal data to comply with local law. Note, however, that SSV 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 SSV is relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on its legitimate interests). In some cases, SSV may demonstrate that it has compelling legitimate grounds to process your information which override your right to object.
• to object at any time to the processing of your personal data for direct marketing purposes.
• request the transfer of your personal data to you or to a third party. SSV 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 SSV to use or where SSV used the information to perform a contract with you.
• withdraw consent at any time where SSV is 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, SSV may not be able to provide certain products or services to you. SSV will advise you if this is the case at the time you withdraw your consent.
• request restriction of processing of your personal data. This enables you to ask SSVs to suspend the processing of your personal data in one of the following scenarios:
• If you want SSV to establish the data's accuracy;
• Where SSV’s use of the data is unlawful but you do not want SSV to erase it;
• Where you need SSV to hold the data even if SSV no longer requires it as you need it to establish, exercise or defend legal claims; or
• You have objected to SSV’s use of your data but SSV needs to verify whether SSV has overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact SSV at info@ssvsmartpay.co.

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, SSV may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, SSV could refuse to comply with your request in these circumstances.

What SSV may need from you

SSV may need to request specific information from you to help it 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. SSV may also contact you to ask you for further information in relation to your request to speed up its response.

Time limit to respond

SSV try to respond to all legitimate requests within one month. Occasionally it could take longer than a month if your request is particularly complex or you have made a number of requests. In this case, SSV will notify you and keep you updated.

Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact SSV in the following ways:

• Email address:  info@ssvsmartpay.co
• Postal address: Level 18, 40 Bank Street, London, E14 5NR
• Telephone number: +44 (0) 203 633 3344

Complaints

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

Changes to the privacy policy and your duty to inform SSV of changes  

SSV keep this privacy policy under regular review. It is important that the personal data SSV holds about you is accurate and current. Please keep SSV informed if your personal data changes during your relationship with SSV, for example a new address or email address.

Third-party links  

This App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. SSV does not control these third-party websites and is not responsible for their privacy statements.  SSV encourages you to read the privacy policy of every website you visit.