Privacy Policy
Introduction
This Privacy Notice (“Notice”) describes the ways Linkpay collects, stores, uses and protects personal data. The Privacy Notice together with Linkpay Terms and Conditions (and any other document referred to therein) describes how we collect, process, use and disclose your information, including any personal data we collect from you, or which you provide to us through the website LinkPay.io (hereinafter referred to as the Website). When you contact us via the Website, complete any forms or submit any details using the Website, we will collect, use and disclose your personal information as described in this Privacy Notice.
Our privacy practices may vary among the countries or territories in which we operate to reflect local practices and legal requirements. The purpose of this Notice is to inform you about the processing of personal data by us and to inform you of your rights.
Responsibility
Compliant processing. Linkpay complies with applicable United States federal and state regulations and European Economic Area (European Union + Norway, Iceland, Liechtenstein) (hereinafter “EEA”) data protection laws, such as the General Data Protection Regulation and its implementation acts (hereinafter “GDPR”).
Linkpay as a controller. Linkpay is considered the controller for processing personal data as described in this Notice.
Linkpay as a processor. In principle, we control the processing of your personal data. However, in some cases, we may process your personal data on behalf of another party, who is the controller responsible for your personal data. This Notice does not relate to that part of our processing activities where we are acting on behalf of another controller. For such processing, the privacy notice of the relevant controller applies, and we encourage you to read that notice.
Third party websites. The Sites may include links to websites of third parties (for example, hyperlinks, banners or buttons). We are not responsible for the content of those websites, services provided by those third parties, or their compliance with applicable privacy legislation.
What is personal data?
Personal information is data about an “identifiable individual”. It is information that on its own or combined with other pieces of data, can identify you as an individual.
The General Data Protection Regulation (GDPR) (EU Regulation 2016/679) defines personal data as «any information relating to an identified or identifiable natural person (data subject), directly or indirectly, by reference to an identifier, such as name, an identification number, location data, an online identifier». Simply put, personal information is any information about you that enables your identification.
The personal data we collect and use is described in this Privacy Notice.
How we obtain personal data
Means of collection. We obtain your personal data in various ways:
- Provided by you. We obtain information provided by you, for example, if you contact us, sign up for our newsletter, or provide information to us in the course of using our Services. When you provide personal data to Linkpay, please do not provide information that is irrelevant, inaccurate, and/or unnecessary for the provision of Services.
- Automatically collected. We obtain some information automatically when you visit our Sites, for example, via cookies. For more information, please see our Cookie Policy.
- Third parties. We may obtain information from third parties, such as our Merchants with which you do business.
- Required provision. It may be that providing certain personal data to us is a statutory or contractual requirement, a requirement necessary to enter into a contract, or that you are otherwise obliged to provide. If that is the case, we will inform you thereof and will explain the possible consequences if you fail to provide such personal data to us.
Who are the data subjects?
There are several types of data subjects whose personal data we process:
- Visitors of our Sites;
- Merchants who sign up for our Services (“Merchants” means any business that uses our Services to process payments, including non-profits that use our Services to accept donations and “Aggregators” that use our Services as a payment services platform for their own Merchants);
- Shoppers of Merchants (“Shoppers” means individuals who indirectly interface with Linkpay when paying a Merchant’s invoice that is forwarded by Linkpay to a Merchant during checkout, when requesting a refund from a Merchant, when creating a Linkpay account, or when making a donation to a non-profit);
- Linkpay wallet holders who have downloaded and installed the Linkpay app on their mobile device;
- Payees (e.g., employees, contractors, vendors or exchange customers) who request a payment (“Payout”) via cryptocurrency from a Merchant and create a Linkpay account; and
- Partner employees (employees and other agents of our customers and vendors, including potential and former customers and vendors).
Details of data processing
What kind of personal data do we collect, why, and on what legal basis?
The categories of personal data we collect, the purposes, and the legal bases are set forth below. Our primary purpose for collecting personal data is to provide you with a secure, smooth, efficient, and customized experience. We use your personal data to:
- Provide our Services (including customer support);
- Process transactions and send notices about your transactions;
- Resolve disputes, collect fees, and troubleshoot problems;
- Communicate with you about our Services and business and to inform you of matters that are important for your account and/or use of the Sites. We also use your personal data to respond to any questions, comments or requests you filed with us and the handling of any complaints;
- Comply with applicable laws and regulations;
- Establish, exercise and defend legal claims;
- Monitor and report compliance issues;
- Customize, measure, and improve our business, the Services, and the content and layout of our website and applications (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services, websites and apps; ensuring the security of our networks and information systems; performing accounting, auditing, invoicing, reconciliation and collection activities; and improving and maintaining the quality of our customer services);
- Perform data analysis;
- Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences, and measure the effectiveness of it. To approach you via email for marketing purposes, we request your consent, unless it is not required by law. You always have the option to unsubscribe from our mailings, e.g., via the unsubscribe link in our newsletter;
- Perform risk management, including comparing information for accuracy and verify it with third parties and protect against, identify and prevent fraud and other prohibited or illegal activity, claims and other liabilities; and Enforce our contractual terms.