This privacy notice describes how P20, Inc. (‘we’, ‘us’) collects and processes personal information about you; how we use and protect this information, and your rights in relation to this information.

This privacy notice applies to all personal information we collect or process about you. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.

1. Personal information we use

We will collect personal information from you directly (e.g. when you contact us or when you login to your account using our website) and we collect personal information automatically when you use our website.

The categories of information that we may collect directly from you include the following:

(a)            personal details (e.g. name, date of birth);

(b)            contact details (e.g. work phone number, work email address, work postal address or work mobile number);

The categories of information we may collect automatically about you include information from cookies and other identifiers we place on your device. We only place cookies or other identifiers on your device where they are necessary for the website to function correctly, or if you have provided your consent.

2. How we use your personal information and the basis on which we use it

We may use your personal information for the following purposes:

  • Identification and authentication: we use your identification information to verify your identity when you login to your account and use our services, and to ensure the security of your personal information. We use your personal information for this purpose so that we can comply with our contractual obligations to you which are set out in the Terms and Conditions.
  • Operating the website: we process your personal information to provide the website and any services on the website which you have requested. This is so we can provide the services to you in line with our contractual obligations to you, which are set out in the Terms and Conditions.
  • Improving our services: we analyse information about how you use our website to provide an improved experience for our customers. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our services to improve it.
  • Communicating with you: we may use any of the categories of your personal information when we communicate with you, for example if we are providing information about changes to the terms and conditions or if you contact us with questions. It is in our legitimate interests that we are able to provide you with appropriate responses and provide you with notice about our services.
  • Exercising our rights: we may use any of the categories of your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or the contract.
  • Marketing: we may use your personal information to personalize the marketing messages we send to you, to make them more relevant and interesting, as this is in our legitimate business interests. Where necessary, we will obtain your consent first.

3. Your rights over your personal information

You have certain rights regarding your personal information, subject to local law. These include the following rights to:

  • access your personal information;
  • rectify the information we hold about you;
  • erase your personal information;
  • restrict our use of your personal information;
  • object to our use of your personal information;
  • receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
  • lodge a complaint with your local data protection authority.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

Please note that we will likely require additional information from you in order to honour your requests.

If you would like to discuss or exercise such rights, please contact us using the details set out below.

4. Information Sharing

We may share your personal information with third parties under the following circumstances:

  • Service providers and business partners. We may share your personal information with our service providers and business partners that perform business operations for us.
  • Our group companies. We work closely with Payments 20 Limited., a subsidiary located in the UK. We may share your personal information about marketing and internal reporting purposes.
  • Law enforcement agencies, courts, regulators, government authorities or other third parties. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
  • Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Policy.

5. Retention of Personal Information

We will retain your personal information so that we can invite you to future events and send you messages about our activities, We will delete your personal information after a certain period if you do not make contact with us or attend any of our events. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations and regulators’ expectations.  We may also retain records to investigate or defend potential legal claims.

6. International Data Transfers

Your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union law. This may include in particular the USA, where we are located.

We put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

7. Contact Us

P20, Inc., with registered address 1180 West Peachtree Street NW, Suite 1800, Atlanta GA 30309, USA is the controller responsible for the personal information we collect and process.

If you have questions or concerns regarding the way in which your personal information has been used, please contact  contact@payments20.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority in your country using their website.

8. Changes to the Policy

You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time. You will be able to see when we last updated the privacy notice because we will include a revision date. Changes and additions to this privacy notice are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your personal information.

19 September 2017