Privacy Policy

INTRODUCTION

This Privacy Policy is intended for those using the website, i.e. Paytiko) (hereinafter the “Website”) or utilizing the services offered by the Tech Solution EOOD, Office 1, Vertigo Business Building, Building № 109, Sofia, Bulgaria (hereinafter the “Company”, “we”, “us” and “our”) and describes how we use or otherwise process your personal data that is received and/or collected by the Company by any person that decides to enter our Website and/or use our Website or decide to use any service available through the Website (hereinafter the “User” or “You”).

Our Company is dedicated to safeguarding your confidentiality and privacy of your personal data and handling or your personal data in a transparent manner all in line and in compliance with the provisions of the applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (hereinafter the “GDPR”).

The Website and the Company’s services are not available to individuals who are under the age of eighteen (18) (hereinafter the “Minors”). We do not knowingly collect personal data from or about Minors. If you are a Minor, you should not download or use any of our services nor provide any personal data to us.

If we become aware that a Minor has shared any information with us, we will delete such information. If you have any reason to believe that a Minor has shared any information with us, please contact us at (support@paytiko.com).

This Privacy Policy does not apply to websites operated by any other entities and/or other third parties.

USEFUL DEFINITIONS

For the purposes of this Policy:

• Cookies: are small data files stored on your hard drive or in device memory that help us improve our services and your experience, see which areas and features of our services are popular and count visits. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org
• Personal Data: means any information that could be used, on its own or in conjunction with other data, to identify an individual, directly or indirectly, such as name, identification number, location data, etc.
• Processing: means any operation or set of operations which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, erasure or destruction.

WHAT PERSONAL DATA WE COLLECT

The Company collects personal data about You in a number of ways, including inter alia, when you visit our Website or communicate with Us by completing the “Contact Us” section via our Website or decide to use our services that are available via our Website.

Automatic collection by Us, including technical data, browsing actions and patterns collected automatically via the utilization of Cookies, server logs and other similar technologies.

From third parties or publicly available information, including Credit Reference Agencies, Payment Services and E-Wallet Providers.

We may collect, use and/or otherwise process the following personal data about You:

HOW WE USE YOUR PERSONAL DATA

We take all appropriate measures to ensure that your personal data is processed lawfully, fairly and in a transparent manner for the following purposes and based on the following lawful bases:

(A)Provision of Services:

We collect, use or otherwise process your personal data (including, Personal Details/Identity, Contact Info and Financial Details) so as to provide you with our services and products and to respectively conclude contracts with you, to carry out our contractual obligations and manage your account with Us.

In this regard, we rely on a contract entered into by You and our Company – Processing Necessary for the performance of a Contract.

(B)Compliance with Legal and Regulatory Requirements:

We also use or otherwise your personal data (including Personal Details/Identity, Contact Info, Financial Details and Transaction) to comply with our regulatory requirements such a client identification or due diligence that are required by the applicable legislative framework on the prevention and suppression of money laundering and terrorist financing, to help prevent fraud, as well as with other legal obligations – Compliance with a Legal Obligation.

(C)Consent:

We also use your personal data so as to carry out various marketing activities and in this regard, we rely on your consent.

When we will have your consent (for instance, you have subscribed to our Newsletter), we shall send you marketing communications by e-mail in order to ensure that you are always up to date with our latest products and services.

You can OPT-OUT of such communications at any time by contacting us at (support@paytiko.com). In doing so you exercise your right to withdraw your consent without affecting the lawfulness of the processing based on consent before withdrawal.

(D)Legitimate Interests:

For improving our services and any troubleshoot issues or to develop our services/products and grow our business, we may process your personal data (including Personal Details/Identity, Contact Info, Financial Details and Transactions).

WHO DO WE SHARE YOUR PERSONAL DATA WITH AND WHY

We shall not disclose any of Your Personal Data to a third party, except where any of the following cases applies:

(a)to the extent that it is required to do so by under and/or pursuant to any applicable laws, rules and/or regulations.

(b)where there is a duty to the public to disclose.

(c)where our legitimate business interests require disclosure.

(d)at your request or with your consent to the parties described below.

Under such circumstances, the Company shall expressly inform the third party regarding the confidential nature of any such information. As part of using your personal data for the purposes set out above, the Company may disclose your personal data to the following:

(a)between and among the Company and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.

(b)our associates, for business purposes, including certain third parties such as service providers and specialist advisers who have been contracted to provide us with administrative, financial, legal, insurance, research or other services.

(c)financial services providers, including card issuers, payment processors and banking partners to facilitate payment transactions.

(d)courts, tribunals, public and regulatory authorities as agreed or authorised by law; and

(e)anyone authorised by you.

When we share your Personal Data to any third parties, such third parties can only use or otherwise process your Personal Data for specific purposes and in accordance with our instructions. We require any third parties who handle or obtain your Personal Data to acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with all relevant data protection laws and this Privacy Policy.

Such third parties may store your Personal Data so as to comply with their own legal and other obligations.

Also, third party service providers such as credit referencing agencies (if and when applicable) may keep a record of any searches performed on our behalf and may use the search details to assist other companies in performing their searches.

Please note that the use of personal data by external third parties who act as data controllers of your personal information is not covered by this Privacy Policy and is not subject to our privacy standards and procedures.

INTERNATIONAL DATA TRANSFERS

We may transfer and/or store the Personal Data we collect from you to entities outside the European Economic Area (the “EEA”). When we do this, we shall ensure that the transfer is lawful, that your data is secured and that the third parties outside of the EEA are obligated to comply and provide appropriate safeguards in relation to the transfer of your Personal Data in accordance with the GDPR.

RETENTION OF PERSONAL DATA & SECURITY

We shall retain your Personal Data, for as long as necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

When we consider that the Personal Data is no longer necessary for the purposes for which they were collected, we shall remove any details that will identify you (if possible) or will shall securely destroy the relevant records. We may however, need to maintain the records of personal for a significant period of time, i.e. we are subject to certain anti-money laundering laws that require us to maintain our records for a period of five (5) years after our business relationship has ended.

Your Personal Data is securely stored in safe location and only authorised personnel have access to it.

Transmission of information via the internet is not always completely secure but we endeavor to protect your personal data by taking serious precautions. Once we have received your information, we will apply procedures and security features to try to prevent unauthorized access.

The Company shall not be liable for unlawful or unauthorised use of any personal information due to misuse or misplacement of the passwords, negligent or malicious use.

YOUR RIGHTS

You have certain rights in respect to the way we use or otherwise process your personal data under the GDPR. Although, we are committed to facilitating the exercise of your rights under the GDPR, these may be only applicable under specific conditions – the below rights might not be absolute rights.

(a)Right of Access

If you ask, we will confirm whether we are processing your personal information. If we do, then if requested we can provide a copy of what information we process within thirty (30) days from the date of your request.

(b)Rectification of personal information

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your personal information to others, we will let them know about the rectification where possible.

We shall update your Personal Data in accordance with your instruction.

(c)Deletion of personal information

If you request us to delete your personal data, subject to certain criteria to being fulfilled where, for instance, your personal data is no longer required in relation to the purposes for which they were originally collected or otherwise processed or you have withdrawn consent (where applicable) provided that we have no legal obligation to retain the data, we will delete them the soonest possible.

(d)Restrictions of Processing

You can request us to restrict our processing activities where certain conditions shall be satisfied, including without limitation, the case where the processing is unlawful, and you oppose the processing of the personal data and request the restriction of their use instead. It will not stop us from storing your personal information though. We will inform you before we waive any restriction.

(e)Portability of data

You have the right to receive your personal data which you provided us in a structured, commonly used and machine-readable format and to transmit this elsewhere or ask us to transfer them to another data controller, to the extent applicable and where this is technically feasible.

(f)Objection / opt-out

You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing; or
• processing your personal information for direct marketing.

Any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn by you.

Should you want us not to use your personal information, you must inform us via email to (support@paytiko.com). If you decide to do so, we may not be able to continue to provide information, services and/or products requested by you and we will have no liability to you in this respect.

(g)Rights relating to automated decision making and profiling

You have the right not be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. Such right means that in cases where we utilize automated decision making or profiling, you are entitled to request one (1) of our employees to be involved in the decision making.

LINKS TO OTHER WEBSITES

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website(s). Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement.

You should exercise caution and look at the privacy statement applicable to the website in question so as to be properly informed about the processing activities of such website(s).

COOKIES

Our Website uses cookies to distinguish you from other users of our Website. Cookies are frequently used on many websites on the Internet, and you can choose if and how a cookie will be accepted by changing your preferences and options in your internet browser.

A cookie is a small text file that a website stores on your computer or mobile device when you visit the site.

For more information on how we use cookies, you are kindly referred to our Cookies Policy.

CONTACT US

In case you would like to contact us in respect of this Privacy Policy or regarding the way we use and/or managing your personal data or you wish to exercise your legal rights as these are deriving from the GDPR and set out herein, please contact us via email at (support@paytiko.com).

In any event, you are entitled to lodge a complaint with the supervisory authority in Bulgaria, i.e. the Personal Data Protection Commission at (www.Paytiko.com).

UPDATES/ CHANGES TO THIS POLICY

We may need to change or update this Privacy Policy from time to time so as to ensure that this remains up to date with the latest legal requirements and any changes implemented with our privacy management practices.

Any changes and/or updates implemented within this Privacy Policy will be posted on the Website and shall be effective from the date when we post our updated Privacy Policy. Hence, the Company encourages you to periodically access our Website, and review the content of our Privacy Policy.

Where required, we will make sure to notify you accordingly about the changes/updates implemented within our Privacy Policy.