Pago Payments provides payment products and services for commercial and non-commercial enterprises. Those products and services include payment card processing, check recovery, cash access services, point-of-sale terminal management and support, merchant accounting and funds transfer. As a part of our payment processing function, we routinely collect and retain personal information about our customers and the third parties with whom our customers do business. For our customers, information about disclosures, transfers and other processing of personal information as part of our payment processing function is set out in the documentation provided to them at the onboarding stage and is outside of the scope of this policy, which relates only to information we obtain through this website.
Personal Information We Obtain
Through this website, subject to your consent if required by law, we may collect the following personal information, as relevant and as is voluntarily supplied to us by you (this is not a definitive list):
- Names and contact details including telephone number, email address and postal address;
- Your username (currently, your email address) and password, both of which you will use to log in to this website (see “Login Details and Your Responsibility” below);
- Products and related services which are of interest to you, as relevant to your preferences (see “Managing Your Preferences” below);
- Information you provide if you report a problem with our website; and
- Records of any correspondence we have with you.
How We Use the Personal Information We Obtain
Subject to your consent if required by law, we may use your personal information for the following reasons (this is not a definitive list):
- To contact you regarding any inquiry you make or to fulfil a request, such as, for example, a request for information about our products and services;
- To improve and personalize your experience when you use this website;
- To improve our products and services and for the development of future products and services;
- For internal record keeping and administration of records;
- For statistical analysis (see “Data Anonymization and Aggregation” below);
- To contact you by email and, if you have signed up for the service, to share e-newsletter or any other updates, communications or publications;
- For direct marketing purposes subject to your consent if required by applicable law (see “Managing Your Preferences” below);
- As necessary to set up and administer your sign up to, and use of, the log in facility available on this website; and
- For compliance with applicable laws and/or regulations and as otherwise required or permitted by applicable laws and/or regulations.
Disclosures of the Personal Information We Collect
We are a multinational business headquartered in the United Kingdom, with subsidiaries and affiliates in various countries around the world. Your personal information may be disclosed to recipients located outside of your country, including our global subsidiaries and affiliates (see “Our Relationship with Affiliate Companies” below), as well as other types of third parties engaged to help us run our business, subject to your consent if required by law. These types of third parties may include distributors of our products and services, service providers retained to perform functions on our behalf or to provide services to us, including (without limitation) legal, accounting, audit, consulting and other professional service providers, and providers of other services related to our business. Portions of our services may be provided by organisations with which Pago Payments has a contractual relationship, including subcontractors, and, accordingly, your personal information may be disclosed to them. We take steps aimed at ensuring that all such persons process your personal information as disclosed by us only as necessary for their service delivery and for no other purpose.
We also may disclose your personal information in order to obtain commercial and credit information to establish, maintain or renew a customer’s contract(s), as may be required to provide any of the services for which a customer has subscribed, to comply with the rules and regulations of any credit or debit card payment network or otherwise in accordance with this policy.
We may also disclose your personal information:
- In response to a court order or a request for cooperation from a regulatory, law enforcement or other government agency; to establish or exercise our legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or regulations;
- When we believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; to protect and defend the rights, property or safety of Pago Payments, its customers, staff, suppliers or others; and
- To purchasers and, subject to local legal requirements, prospective purchasers in the event that Pago Payments and/or its global affiliate companies (as applicable) disposes of, or considers the disposition of, any of its/their business or assets.
We do not make a practice of selling, sharing, trading or renting your personal information to others in ways different from what is disclosed within this policy, agreed to contractually by our customers or otherwise with their permission; provided, if you were referred to Pago Payments for services via a third party, such as another independent services provider, we may share information with such third party in accordance with our business relationship with you and that third party.
Our Relationship with Affiliate Companies (Including Disclosures and Transfers)
Subject to your consent if required by law, we may appoint an affiliate company to process personal information in a service provider role for and on our behalf. This could be the case if, for example, we permit customers to access electronic statements for their accounts. In that scenario, if there is a charge for the service, customers will pay us for the online access service, but it may be an affiliate company which processes the relevant personal information. In most cases, we will remain responsible for that company’s processing of your personal information pursuant to applicable data privacy laws.
Login Details and Your Responsibility
Subject to your consent if required by law, we will collect and process your personal information as necessary to set up and administer your sign up to, and use of, the log in facility available on this website. We will use “cookies” to “remember” the machine or other device you use to access this website (see “Cookies” below). Please remember that if we contact you, we will never ask you for your password in an unsolicited email, message or phone call. If you choose to use the log in facility available on this website, you are required to adhere to the following security procedures in relation to your username (currently, your email address) and password, which are referred to as “login information”:
- Keep your login information secret and secure at all times and do not disclose it to any other person or allow any other person to use it;
- Do not write down or record in any form your login information or store it on any software, including a password save feature;
- Destroy any notice from us concerning your login information as soon as you have read and understood it;
- Should you become aware or have reason to suspect that your login information has been lost or disclosed to, or seen or accessed by, someone other than yourself, immediately notify Pago Payments at the email address provided above;
- Do not leave your computer or other device unattended while you are using the log in facility available on this website or let anyone else use your computer or other device unless and until you have logged out; and
- Use particular caution if you access the log in facility available on this website from a public or shared computer, to ensure that other people are not able to see seen your login details.
Managing Your Preferences
Subject to your consent if required by applicable law, we may use your personal information to provide you with direct marketing information about our products and services as well as those of our global affiliates and third parties, and we may permit those affiliates or other third parties to send their own direct marketing to you. Our direct marketing may be by email, telephone, post or SMS or such other method(s) as may become relevant. In addition, Pago Payments may provide direct marketing information and permit others to do that as allowed by our customers’ respective contracts.
We will take steps to seek to ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.
Obtaining Copies of or Access to Your Personal Information and Updating Us
You may have the right to obtain copies of or access to your personal information from us. Please contact us for further details. We may request payment of a small fee, in accordance with applicable law. If you believe that any information we have about you is incorrect or incomplete and should be updated, please inform us as soon as possible.
Data Anonymisation and Aggregation
Subject to your consent if required by law, we may anonymize or aggregate your personal information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymised or aggregated data, for example, for statistical analysis and administration including analysis of trends, to carry out actuarial work, to tailor products and services and to conduct risk assessment and analysis of costs and charges in relation to our products and services. We may share anonymized or aggregated data with our global affiliates and with other third parties. This policy does not restrict Pago Payments’ use or sharing of any non-personal, summarized, derived, anonymised or aggregated information (i.e., volumes, totals, averages, etc.).
Commitment to Security, Privacy and Standards
We take seriously our responsibility to protect the security and privacy of the information we receive via this website. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide via this website against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorised action involving our information systems, is regarded as potential criminal activity. Suspected computer mischief may be reported to the appropriate authorities.
Please remember that communications over the internet such as emails are not secure. We seek to keep secure all confidential information and personal information submitted to us through this website in accordance with our obligations under applicable laws and regulations. However, like all website operators, we cannot guarantee the security of any data transmitted through this website.
An IP address is a number which recognises the computer or other device used to access the internet. Typically, a web server automatically collects IP addresses and uses them to administer a website. IP addresses are used in conjunction with cookies for the purpose of “remembering” computers or other devices used to access this Website. For further details, see “Cookies” below.
A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. This website’s uses of cookies includes those cookies that are strictly necessary to enable the features of the website, performance cookies to see how visitors use the website, and functionality cookies that enable the webpage to “remember” machines or devices, personalize website content and tailor user experience. In addition, cookies may be used to help us define our audience so that we can make appropriate changes to this website (“Demographics” cookies) and target advertisements to users when they are browsing this website and other websites (“Interest Reporting” cookies), in each case by reference to anonymous identifiers, not personal information. Additional information about the types of cookies we may use is provided below.
Classification of Cookies
Cookies can be classified by duration and by source:
- Duration. This website uses both “session” and “persistent” cookies. “Session” cookies are temporary, and they are destroyed when you close the browser and terminate your ‘active session’ during which you visited this website. “Persistent” cookies remember you on subsequent visits. “Persistent” cookies are not deleted when you close your browser, and they will remain on your computer or other device unless you choose to disable them (see below for how to disable cookies). “Persistent” cookies include the “Interest Reporting” and “Demographics” cookies.
- Source. Cookies can be “first-party” or “third-party” cookies, which means that they are either issued by or on behalf of Pago Payments or by a third-party operator of another website. For an example of a third-party cookie, our website may contain a Facebook “like” button, which would set a cookie that can be read by Facebook. This website may use both first-party and third-party cookies.
Function of Cookies
The cookies that we may use on this website fall into the following categories:
- Essential (“strictly necessary”) Cookies. These cookies are essential in order to enable you to navigate this website and use its features. They are deleted when you close the browser.
- Analytical/Performance Cookies. These cookies collect information in an anonymous form about how visitors use this website. They allow us to recognize and count the number of visitors and to see how visitors navigate this website. For further details see “Google Analytics” below.
- Interest Reporting and Demographics Cookies. These cookies use anonymous identifiers to track users’ browsing habits on this and other websites as they browse pages, videos and content, which allow us to define our audience so we can make appropriate changes to this website and target advertisements to users on this and other websites.
This website may link through to third-party websites, and that linking process may involve the placement of third-party cookies on your machine or other device.
We do not control the third-party cookies used for any of these purposes. You should read any other applicable privacy and cookies policies carefully before clicking on an external link that directs you away from this website. See “External Links” below.
Types of Cookies We May Use
This table summarizes the cookies which may be set on your machine or other device when it is used to access this website, together with their function, duration and source.
|__utma||2 years||This Google analytical cookie tracks the number of times a user visits the site.|
|__utmb||30 minutes||These Google analytical cookies work together to calculate the amount of time users spend on the website in each session.|
|__utmc||End of session|
|__utmz||6 months||This Google analytical cookie tracks the search engine from which a user accesses the site and which search terms were used to find the site.|
|__utmv||2 years||This Google analytical cookie tracks user behaviour and measures site performance. The cookie enables us to remember user preferences.|
|sc_analytics_global_cookie||10 years||These analytics cookies are used to identify repeat visits from a single user and track behaviours through the site.|
|Sc_analytics_session_cookie||End of session|
To opt out of being tracked by Google Analytics, visit Google Analytics.
Demographics and Interest Reporting Cookies
This website uses Google Analytics Demographics and Interest Reporting cookies, a type of Google analytics cookies. To implement its Demographics and Interest Reporting features, Google installs its own advertising cookies and anonymous identifiers to collect data about traffic on this and other websites. We do not merge personal information with non-personal information collected through the Google Analytics Demographics and Interest Reporting cookies. We use the data collected by the Demographics and Interest Reporting cookies (in combination with the other Google analytics cookies described herein) to:
- Determine if we are getting more hits on certain pages of this website, for example, when accessed by mobile devices, so that we can make appropriate adjustments to those pages to make them more user friendly;
- Determine if this website or certain pages of this website are more popular in certain geographical locations or among a certain demographic so that we can tailor those pages to users for a better experience;
- Recognize user preferences, make improvements to this website, and choose content and advertising to display to users on this and other websites based on their browsing habits;
- Deliver advertisements that are more relevant to users and their interests and demographics; and
- Reach users who might be interested in products and services similar to those offered by us, including when those users are browsing other websites, using apps or watching videos, based on their interests inferred from their browsing activity.
When users visit this or another website, Google stores a number in their browsers using a cookie to remember their visits. This number uniquely identifies a web browser on a specific computer or other device, not a specific person. Browsers may be associated with a demographic category, such as gender, age range, or parental status, based on the sites that were visited. Users can edit their suggested demographic categories for websites by visiting Ads Settings at www.google.com/settings/ads.
Users can opt out of being tracked by Google Analytics Demographics and Interest Reporting cookies through Google Ads Settings here, by installing a Google Analytics Opt-Out Browser Add-on here or by visiting the Google Analytics opt-out page here.
How to Delete or Block Cookies at Any Time
You may delete or block cookies at any time by changing your browser settings. Click “Help” in the toolbar of your browser for instructions, or review the cookie management guide produced by the Interactive Advertising Bureau – www.allaboutcookies.org. If you delete or block cookies, some of the features on this Website may not function properly. Some browsers have a “do not track” feature that allows you notify websites that you do not want to have your online activities tracked. At this time, our website does not respond to “do not track” requests from browsers.
Pago Payments may provide links on this website to other websites that are not under our control. We do not endorse or make any warranty of any type regarding the content contained on such websites or products and services offered on those websites. We make no representation regarding your use of such websites. Please be aware that we are not responsible for the privacy practices of the operators of other websites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personal information. This policy applies solely to information collected by us. You should read any other applicable privacy and cookies policies carefully before accessing and using such other websites.
Changes and Updates
We may change this policy from time to time by updating this page. We will not necessarily bring changes or updates to your attention, so please revisit this page periodically to re-read this policy and to ensure you are aware of any changes when you visit the website. If there are substantive changes, including to the cookies we use, at our discretion, we may bring those to your attention, for example, by a message posted on the landing page of this website, which all users see on their next visit, or by a repeat cookies banner.
This Website is not intended for use by children. We do not solicit or knowingly accept any personal information from persons under the age of 18. Please do not use this website if you are under the age of 18.
Users in the following regions and countries should read the sections below, which contain additional information about regional-specific privacy laws and regulations. In the event of conflict between the information above and the sections below, the sections below will prevail for the regions and countries specified.
Users in the European Economic Area
Your personal information may be processed in countries outside the European Economic Area (“EEA”) which may not have data privacy laws equivalent to those in the EEA. This includes transfers between Pago Payments and its global affiliates and to the other third parties as described in the previous paragraphs (as relevant). The relevant Pago Payments companies will take the necessary measures to ensure protection of your personal data collected through this website in accordance with applicable data privacy laws.
European Union: Data Controller Identification
The relevant Pago Payments subsidiary in your country will be responsible under applicable privacy laws to the extent it uses your personal information for its own purposes. If Pago Payments Ltd. or any of its other subsidiaries uses your personal information for its own purposes, for example, to provide payment processing services to you, that entity may also be responsible under any privacy laws applicable to it. A list of all other Pago Payments subsidiaries in all other countries that may use your personal information for its own purpose is available upon request.