1. About this Privacy Statement
This is the Privacy Statement of ALTERNATIVE PAYMENT SYSTEMS INC.B.V. (“APS”), a private corporation incorporated under the laws of the State of Delaware. It applies to all subsidiaries and branches of ALTERNATIVE PAYMENT SYSTEMS INC.to the extent that they process personal data.
ALTERNATIVE PAYMENT SYSTEMS INC. treats personal data which it receives through its websites, portals and any other means with due care and is dedicated to safeguarding any personal data it receives. ALTERNATIVE PAYMENT SYSTEMS INC.is bound by the General Data Protection Regulation.
This Privacy Statement is designed to advise you about the type of information that ALTERNATIVE PAYMENT SYSTEMS INC. collects and the purposes for which this information is being processed, used, maintained and disclosed.
This Privacy Statement aims to explain in a simple and transparent way what personal data we gather about you and how we process it. It applies to the following persons:
• the legal representatives and ultimate beneficial owners of all past, present and prospective ALTERNATIVE PAYMENT SYSTEMS INC. merchants (web shops/online retailers) and other commercial contracting parties such as independent sales agents (also known as referral partners). We are legally obliged to retain personal data of these persons, also for a certain period after the relationship has ended.
• anyone visiting the ALTERNATIVE PAYMENT SYSTEMS INC. website.
We may amend this Privacy Statement to remain compliant with any changes in law and/or to reflect how our business processes personal data. This version was created on 9/6/18. The most recent version is available at www.APSRISK.net
2. Personal Data
Personal data refers to any information that tells us something about you or that we can link to you. ALTERNATIVE PAYMENT SYSTEMS INC. processes any information we receive from you, including personal and financial information you provide to us including when you or your business: make a payment, enquire or make an application for APSCORPORATION’s services, register to use and/or use any of our services and when you communicate with us through e-mail, SMS, WhatsApp, a website or portal, telephone or any other electronic means. Such information may include you or your customer’s: • name including first name and family name, date of birth, e-mail address, billing address, username, password and/or photograph, address, nationality and country of residence; • card account number, card expiry date, CVC details, bank and/or issuer details; and/or • information relating to any items purchased, including the location of the purchase, the value, the time and any feedback that is given in relation to such purchase.
By processing we mean everything we can do with this data such as collecting, recording, storing, adjusting, organizing, using, disclosing, transferring or deleting. For more information about the way we use your personal data, please refer to Section 4 (What we do with your personal data).
You share personal information with us, for example when you: visit our website, complete a(n) (online) (application) form, sign a contract, make a payment or alternatively use our payment services, or contact us through one of our channels.
We also use data that is legally available from public sources such as commercial registers, debtor registers and the media, or data that is legitimately provided by other companies within the ALTERNATIVE PAYMENT SYSTEMS INC. Group or by third parties.
3. Sensitive data
We do not record sensitive data relating to your health, ethnicity, religious or political beliefs unless it is strictly necessary. When we do it is limited to specific circumstances, for example if you as a customer of a ALTERNATIVE PAYMENT SYSTEMS INC. merchant make a payment for a membership fee to a political party or religious organization.
4. What we do with your personal data
We only use your personal data for legitimate business reasons. This includes:
• Administration. When you open a merchant account we are legally obliged to collect personal data that verifies your identity (such as a copy of your ID card or passport) and to assess whether we can accept you or your company as a customer. We also need to know your address or phone number to contact you.
• Managing customer relationships. We may ask you for feedback about our products and services and share this with certain members of our staff to improve our offering. We might also use notes from conversations we have with you online, by telephone or in person to customize products and services for you.
• Credit risk. To assess the financial position of your company we apply specific risk models that may involve the use of personal data.
• Personalized marketing. We may send you letters, emails, or text messages offering you a product or service based on your personal circumstances or show you such an offer when you log in to our website or mobile apps. You may unsubscribe from such personalized offers. You have the right, not to consent or to object to personalized direct marketing or commercial activities, including profiling related to these activities.
• Providing you with the best-suited products and services. When you visit our website, call our customer service center or visit a branch we gather information about you. We analyses this information to identify your potential needs and assess the suitability of products or services. For example, we may suggest investment opportunities suited to your profile. We analyze your payment behavior, such as large amounts entering or leaving your account. We assess your needs in relation to key moments when a specific financial product or service may be relevant for you, such as starting your first job or buying a home. We assess your interests based on simulations you participate in on our website.
• Improving and developing products and services: Analyzing how you use our products and services helps us understand more about you and shows us where we can improve. For instance, or when you open a merchant account, we measure the time it takes until your first transaction to understand how quickly you are able to use your merchant account.
• we analyze data on transactions between you and our corporate customers (merchants) to offer information services. When ALTERNATIVE PAYMENT SYSTEMS INC. processes personal data for this purpose, aggregated data may be made available to the ALTERNATIVE PAYMENT SYSTEMS INC. merchant.
• we analyze the results of our marketing activities to measure their effectiveness and the relevance of our campaigns.
• Preventing and detecting fraud and data security: We have a duty to protect your personal data and to prevent, detect and contain data breaches. This includes information we are obliged to collect about you, for example to comply with regulations against money laundering, terrorism financing and tax fraud. o We may process your personal information to protect you and your assets from fraudulent activities, for example if you are the victim of identity theft, if your personal data was disclosed or if you are hacked.
• We may use certain information about you for profiling (e.g. name, account number, age, nationality, IP address, etc.) to quickly and efficiently detect a particular crime and the person behind it.
• Our merchants (web shops/online retailers) may use contact and security data to secure transactions and communications made via remote channels.
• Internal and external reporting: We process your data for our payment operations and to help our management make better decisions about our operations and services. To comply with a range of legal obligations and statutory requirements (anti-money laundering legislation and tax legislation, for example).
Data that we process for any other reason is anonymized or we remove as much of the personal information as possible
5. Who we share your data with and why
Whenever we share personal data internally or with third parties in other countries, we ensure the necessary safeguards are in place to protect it. For this, ALTERNATIVE PAYMENT SYSTEMS INC. relies on:
• Privacy Shield framework that protects personal data transferred to the United States.
To be able to offer you the best possible services and remain competitive in our business, we share certain data both internally as well as outside of the ALTERNATIVE PAYMENT SYSTEMS INC. Group. This includes:
ALTERNATIVE PAYMENT SYSTEMS INC. entities
We transfer data across ALTERNATIVE PAYMENT SYSTEMS INC. businesses and branches for operational, regulatory or reporting purposes, for example to comply with certain laws, secure IT systems or provide certain services (see section 4 (What we do with your personal data). We may also transfer data to centralized storage systems or to process it globally for more efficiency.
Independent sales agents
We share information with independent sales agents (referral partners) who act on our behalf.
To comply with our regulatory obligations, we may disclose data to the relevant authorities, for example to counter terrorism and prevent money laundering.
In some cases, we are obliged by law to share your data with external parties, including:
• public authorities, regulators and supervisory bodies such as fraud protection agencies and the central banks of the countries where we operate;
• judicial/investigative authorities such as the police, public prosecutors, courts and arbitration/mediation bodies on their express and legal request; and
• lawyers, for example, in case of a claim or bankruptcy, trustees who take care of other parties’ interests and company auditors.
Third party service providers
When we use other service providers we only share personal data that is required for the particular task we involve the service provider for. Service providers support us with activities like: • performing certain services and operations; • designing and maintenance of internet-based tools and applications; • marketing activities or events and managing customer communications; • preparing reports and statistics, printing materials and designing products; and • placing advertisements on apps, websites and social media.
The ALTERNATIVE PAYMENT SYSTEMS INC. Group may buy or sell business units or affiliates. In such circumstances, we may transfer customer information as a business asset. Without limiting the foregoing, if our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.
With your permission
Your information may also be used for other purposes for which you give your specific permission, or when required by law or where permitted under the terms of the laws of the relevant jurisdiction.
1. Functional cookies
These cookies may store your browser name, the type of computer and technical information about your means of connection to this website, such as the operating system and the Internet Service Providers utilized and other similar information. This information is used to technically facilitate the navigation and use of this website. In addition, functional cookies may be used to store personal settings, such as language, or to remember your information for next visits if so requested.
2. Analytics cookies
This website also uses analytics cookies placed by Google Analytics (including Google Tag Manager) to measure the number of visits and the parts of the website that are the most popular among our website visitors as well as for benchmarking purposes. This information is used to provide aggregated and statistical information on the use of this website and is used to improve the contents of this website to enhance your user experience. ALTERNATIVE PAYMENT SYSTEMS INC. has followed the United States Data Protection Authority in order to ensure that Google Analytics is used in a privacy friendly manner.
3. Third-party/social media cookies
This website contains cookies from third-party websites, mainly social media cookies. When placed on your computer, they automatically activate handy extras, for example, a Facebook ‘like’ button or a Twitter messaging option. These cookies inform our website whether you are logged into such social media and they also enable you to share parts of this website on social media.
Do you object to cookies?
Cookies generally process your IP-address, but they do not save your personal information like e-mail address or phone number. If you do not want to have cookies stored on your computer or want to remove cookies that have already been stored, you can arrange this via your browser settings.
7. How we protect your personal data
We apply an internal framework of policies and minimum standards to keep your data safe. These policies and standards are periodically updated to keep them up to date with regulations and market developments. More specifically and in accordance with the law, we take appropriate technical and organizational measures (policies and procedures, IT security etc.) to ensure the confidentiality and integrity of your personal data and the way it’s processed.
In addition, ALTERNATIVE PAYMENT SYSTEMS INC. employees are subject to confidentiality and may not disclose your personal data unlawfully or unnecessarily.
8. What you can do to help us keep your data safe
Unfortunately, the transmission of information via the internet in general is not always completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We do our utmost to protect your data, but there are certain things you can do too:
• install anti-virus software, anti-spyware software and a firewall on your computer and keep them updated;
• do not leave verification tokens or your credit card) unattended;
• keep your passwords strictly confidential and use strong passwords, i.e. avoid obvious combinations of letters and figures; and • be alert online and learn how to spot unusual activity, such as a new website address or phishing emails requesting personal information.
9. Contact us
If you want to know more about ALTERNATIVE PAYMENT SYSTEMS INC. data policies and how we use your personal data, you can send us an e-mail firstname.lastname@example.org