SSV’s Privacy and Cookies Policy
Introduction
This privacy policy sets out how SSV uses and protects your personal data.
1. Important information about SSV
This privacy policy gives you information about how SSV Smartpay Limited (SSV), a company incorporated and registered in England and Wales with company number 15424021, whose registered office is Level 18, 40 Bank Street, Canary Wharf, London E14 5NR, UK, collects and uses your personal data through your use of SSV’s website.
This website is not intended for children and SSV does not knowingly collect data relating to children.
In addition to this policy, the SSV Consumer/Merchant App Privacy Policy may apply, and which version of that policy applies depends on whether you are a consumer or business
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.
2. The types of personal data SSV collects about you under this policy
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 website.
· 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.
· Marketing and Communications Data includes your preferences in receiving marketing from SSV and third parties and your communication preferences.
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.
3. How is your personal data collected?
SSV uses different methods to collect data from and about you including through:
· Your interactions with SSV. You may give SSV your personal data by filling in online forms or by corresponding with SSV by post, phone, email or otherwise. This includes personal data you provide when you:
· apply for SSV’s products or services;
· create an account on SSV’s platform;
· subscribe to SSV’s service;
· request marketing to be sent to you; or
· give SSV feedback or contact SSV.
· Automated technologies or interactions. As you interact with SSV’s website and services, SSV will automatically collect Technical Data about your equipment, browsing actions and patterns. SSV collect this personal data by using cookies, server logs and other similar technologies. Please see the cookie policy below for further details.
· Third parties or publicly available sources. SSV will receive personal data about you from various third parties and public sources.
4. How SSV uses your personal data
Purposes for which SSV will use your personal data
Set out below is a description of the ways SSV may use the various categories of your personal data, and which of the legal bases SSV relies on to do so.
|
Purpose/Use |
Type of data |
Legal basis |
|
To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To manage relationship with you which will include: (a) Notifying you about changes to SSV’s terms or privacy policy (b) Dealing with your requests, complaints and queries |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for SSV’s legitimate interests (to keep its records updated and manage its relationship with you |
|
To enable you to complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for SSV’s legitimate interests (to study how customers use its products/services, to develop them and grow its business)
|
|
To administer and protect SSV’s business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for SSV’s legitimate interests (for running its business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising SSV serves to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for SSV’s legitimate interests (to study how customers use SSV’s products/services, to develop them, to grow its business and to inform its marketing strategy) |
|
To use data analytics to improve SSV’s website, products/services, customer relationships and experiences and to measure the effectiveness of its communications and marketing |
(a) Technical (b) Usage |
Necessary for SSV’s legitimate interests (to define types of customers for its products and services, to keep its website updated and relevant, to develop its business and to inform its marketing strategy) |
|
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for SSV’s legitimate interests (to carry out direct marketing, develop its products/services and grow its business)
|
|
To carry out market research through your voluntary participation in surveys |
|
Necessary for SSV’s legitimate interests (to study how customers use its products/services and to help SSV improve and develop its products and services). |
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.
SSV will get your express consent before SSV shares your personal data with any third party for their own direct marketing purposes.
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.
4. Disclosures of your personal data
SSV may share your personal data where necessary with the parties set out below for the purposes set out in the table above.
· Business partners for the purpose of fulfilling and administering the contract SSV enters into with you
· 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.
SSV requires all third parties to respect the security of your personal data and to treat it in accordance with the law. SSV does not allow its third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with SSV’s instructions.
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.
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.
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.
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.
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.
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.
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.
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: SSV Capital Ltd, Level 18, 40 Bank Street, Canary Wharf, London, E14 5NR
· Telephone number: +44 (0) 203 633 3344
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.
11. 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.
This website 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. When you leave this website, SSV encourages you to read the privacy policy of every website you visit.
COOKIES POLICY
This website uses cookies to distinguish you from other users. This helps SSV to provide you with a good experience when you browse its website and also allows SSV to make improvements.
A cookie is a small file of letters and numbers that SSV stores on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
SSV uses the following cookies:
· Strictly necessary cookies. These are cookies that are required for the operation of the website. These essential cookies are always enabled because the website will not work properly without them. They include, for example, cookies that enable you to log into secure areas of the website. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of the website.
· Analytical or performance cookies. These allow SSV to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps SSV to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
· Functionality cookies. These are used to recognise you when you return to the website. This enables SSV to personalise content for you, greet you by name and remember your preferences (for example, your choice of language or region).
· Targeting cookies. These cookies record your visit to the website, the pages you have visited and the links you have followed. SSV will use this information to make the website and the advertising displayed on it more relevant to your interests.
You can find more information about the individual cookies SSV uses and the purposes for which SSV uses them in the table below:
|
Cookie Title Cookie Name |
Purpose |
More information |
|
[COOKIE TITLE] [COOKIE NAME]
.AspNetCore.Identity.Application
.AspNetCore.Antiforgery.[random string] |
[DESCRIPTION OF THE PURPOSE FOR WHICH THE COOKIE IS USED AND ITS DURATION]
This is the primary authentication cookie used by ASP.NET Core Identity. It contains the authentication ticket (claims) for the signed-in user. Contents: The cookie stores information such as the user's identity (e.g., user ID, username, roles, and other claims). Usage: The cookie is used by the authentication middleware to identify the user in subsequent requests. This cookie is encrypted and secure to prevent tampering.
Lifespan: By default, the cookie is valid for the duration of the session, but this can be configured (e.g., to use a sliding expiration or to persist the cookie for a specific time).
This cookie is used for Anti-Forgery protection, specifically to prevent Cross-Site Request Forgery (CSRF) attacks.
Contents: It contains a token that is matched with a hidden form field token to verify that the request is legitimate.
Usage: When forms are posted back to the server, the server checks the antiforgery token in the form against the one in this cookie to ensure the request is not forged. Lifespan: This cookie typically lasts for the duration of the session. Examples of purposes for which a cookie may be used: This cookie [is essential for our site to OR enables us to]: [(a) Estimate our audience size and understand how our website it used.] [(b) Store information about your browsing preferences, and so allow us to customise our site and to provide you with offers that are targeted to your individual interests.] [(c) Speed up your searches.] [(d) Recognise you when you return to our site.] [(e) Allow you to use our site in a way that makes your browsing experience more convenient, for example, by allowing you to store items in an electronic shopping basket between visits. If you register with us or complete our online forms, we will use cookies to remember your details during your current visit, and any future visits provided the cookie was not deleted in the interim.] [(f) [OTHER PURPOSES].] |
[LINK TO EXTERNAL INFORMATION WHERE APPROPRIATE] |
Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:
[NAME THIRD PARTIES]
To deactivate the use of third party advertising cookies, you may visit the relevant consumer page to manage the use of these types of cookies [include link to consent management solution]].
[To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.]
OR
[SSV does not share the information collected by the cookies with any third parties.]
You can choose which analytical, functionality and targeting cookies we can set by clicking on the button(s):
Strictly necessary cookies ALWAYS ACTIVE
Analytical or performance cookies OFF
You can also choose to "Reject All" cookies in the cookie banner.
However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website.
Except for essential cookies, all cookies will expire after [EXPIRY PERIOD].
If you have any questions or concerns about our use of cookies, please send us an email at info@ssvsmartpay.co.
Autofill for OTPs: Our application uses autofill functionality solely for the purpose of automatically filling in the One-Time Password (OTP) during registration for user convenience. We do not store, use, or share this information for any other purposes.