MATERIAL SCOPE
This Privacy policy relates to all Users of the website: www.vertipay.net , located in the European union („the Union “) and United Kingdom.
The Privacy Policy refers also to the California consumers. More information about the California consumers’ personal data processing, you can find in the section “CALIFORNIA CONSUMERS” of this policy.
DEFINITIONS:
"Controller" means the entity VertiPay Ltd , because it determines the purposes and means of the processing of personal data;
"Personal Data" means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, etc.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation, alteration, etc.
“Minor” means a natural person under the age of 13.
IDENTITY AND CONTACT DETAILS:
Information about the Controller
“VERTIPAY” Ltd
“Shesti Septemvri” bld, 254, 4006, 3rd Eastern Industrial Zone, Plovdiv
Republic of Bulgaria
Email: legal@vertipay.net
WWW.VERTIPAY.NET USERS:
This section is designed to provide information about our personal data processing practices, such as the types of personal data we collect regarding visitors to the website www.vertipay.net
This section does not cover any information collected by VertiPay Ltd offline or by the mobile application VertiPay.
CATEGORIES OF PERSONAL DATA WE PROCESS. PURPOSES AND LEGAL BASES.
To access or take advantage of some areas of the website, we may ask you to provide personal data.
Personal data may be requested and collected at various locations and on various forms on the website, including, but not limited to e-mail communications; submitting an inquiry via the website or when you communicate or otherwise interact with us via the website. You may always elect not to submit Personal data, however, as a result, you may not be able to access certain features and functionality of the website.
We collect and process personal data that are only necessary for the operation of the website limited to the purposes listed in Table 1.
Table 1 showcases the categories of your personal data, that we process through the website for what purpose and on what legal basis:
Table 1
Log files:
We collect:
• Internet (IP) address;
• Web browser;
• Session history;
Why we collect:
• To maintain our website and prevent it from cyberthreats including DDoS and botnet attacks;
Legal basis for processing:
• Legitimate interest (Art. 6(1)(f) GDPR).
Contact form
We collect:
• E-mail address;
Why we collect:
• To answer your questions and provide relevant information to You in timely manner. Legal basis for processing:
• Legitimate interest (Art. 6(1)(f) GDPR).
PERSONAL DATA AND LOGGING
To maintain our website and prevent it from cyberthreats such as DDoS and botnet attacks, we log every visit to the website including IP addresses and other technical information. As stated by CJEU, your IP address sometimes may constitute personal data. That is why, we treat all IP addresses as personal data under GDPR all the time. Therefore, your IP address is personal data for us and is processed us every time you interact with the website.
PERSONAL DATA AND CONTACT FORM
In order to provide you with all requested information and answer your questions in timely manner we have a Contact Form on our website. The Contact Form is placed in the upper right corner and is titled “Contact us”.
It is possible You to share some personal data with us through the Contact Form. Such personal data includes e-mail and any other information containing personal data you decide to share with us. The legitimate interests of ours for processing this personal data are related to provide quality customer service to You and high-quality user experience. We will erase any information containing personal data you have provided that is not necessary for us to provide you the requested information.
We strongly recommend not to provide any unnecessary information for the sake of your inquiry containing personal data through the Contact Form.
EXCESSIVE AND UNNECESSARY PERSONAL DATA
We encourage you to provide accurate and limited to what is expected volume of information where required within the website.
CHILDREN’S PERSONAL DATA
VertiPay Ltd is aware of the heightened need to protect the privacy of children under the age of 13. Our website is not intended for children and is not targeted to children under the age of 13. Vertipay Ltd does not knowingly collect data from children and, if we learn that we have received personal data from a user under the age of 13, we will delete this data asap.
AUTOMATED INDIVIDUAL DECISION-MAKING
You are not object to a decision based solely on automated processing, including profiling, while visiting and interacting with the website.
PASSIVE COLLECTION OF INFORMATION
In addition to the data that you actively provide to us, we or our third-party service providers may use a variety of technologies to automatically collect information about you when you use the website. This information may include demographic information, browser type, operating system, IP address, mobile device identifiers and other information. This information may also include clickstream data, which is information about the page-by-page paths you take as you browse through the website.
The methods that we and our service providers may use to automatically collect such information include the following:
Web Beacons: We may include small graphic images called web beacons, also known as "Internet tags" or "clear gifs," in our website and e-mail messages. We may use web beacons or similar technologies for a number of purposes, including, without limitation, to count the number of visitors to the website, to monitor how users navigate the website, or to count how many e-mails that we sent were actually opened.
Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the website. It is temporarily downloaded onto your computer from our web server or a third party we work with, and is active only while you are connected to the website, and is deleted or deactivated thereafter.
Passively-collected information about you, such as how you interact with the website may be combined or associated with your Personal data. If we associate any such passively-collected information with Personal data about you, we will treat the combined information as Personal data. We will apply this section of the Privacy Policy to any information received, unless otherwise specifically disclosed by us.
RECIPIENTS OF YOUR PERSONAL DATA
We may share your personal data with some recipients including third party when:
• We are subject to legal obligation to do that;
• It is necessary for the proper operation of the website; or
• We have legitimate interest to do so (necessary for the establishment, exercise or defense of legal claims).
The processors we engage are not allowed to process your personal data for their own purposes. The processors we engage process your personal data only:
• For specified purposes defined by VERTIPAY Ltd; and
• In accordance to our instructions.
TRANSFER OF YOUR PERSONAL DATA TO THIRD COUNTRIES OR MULTINATIONAL ORGANIZATIONS
We do not transfer your personal data to third countries or multinational organizations. If we transfer personal data to third countries or multinational organizations, necessary steps to ensure compliance with the applicable law will be taken.
SECURITY OF YOUR PERSONAL DATA
Your personal data are secured by the latest state of the art technologies. We have implemented adequate technical and organizational measures for security to prevent from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your personal data.
Nevertheless, the access to your personal data is strictly limited to persons that are related and authorized to access to your personal data. They process your personal data in accordance with our instructions and are under confidentiality obligation.
We have implemented strict procedures for dealing with any supposed data breach, related to personal data, and will notify you and the competent data protection authority (DPA) in case of data breach, when we are obliged to do so.
STORAGE PERIOD
We process your personal data as you use the website. We hold onto different types of data for different periods of time. Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary. We store your personal data, described in Table 1. as follows:
Log files: The collected data is typically stored for about 6 months in the server logs. However, we may store the information for a longer period, if there is reasonable suspicion of unlawful use due to indications.
Contact Form data: We store the information only for the period of time which is necessary to answer your questions and provide relevant information to you.
EXERCISE YOUR DATA SUBJECT RIGHTS
Depending on the legal basis for processing your personal data as a data subject you can exercise any of the following rights (unless statutory restrictions apply):
• Right of access. You have the right to access to your personal data we process and inspect how we process them;
• Right to rectification. You have the right to have your incomplete personal data completed, including by means of providing a supplementary statement;
• Right to erasure. You have the right to obtain the erasure of your personal data concerning without undue delay and we have the obligation to erase personal data without undue delay where certain grounds apply;
• Right to restriction of processing. You have the right to obtain restriction of processing Your personal data where a certain ground applies;
• Right to object. You have the right to object at any time to processing of personal data concerning you.
Where we have reasonable doubts concerning your identity when making a Data Subject Request, we may request the provision of additional information necessary to confirm your identity. This precautionary measure guarantees that any of your personal data will not be exposed before unauthorized party.
You can make the Request by electronic form emailing legal@vertipay.net your Data Subject Request, including the following information:
• Identification details – First and last name;
• Contact details - email, mailing address;
• Subject matter of the Request;
• Preferable means of receiving the information.
RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
You have the right at any time to lodge a Complaint with a supervisory authority (Data Protection Authority) of the Member State you are citizen of or residing on its territory.
Contact details of Data Protection Authorities: https://edpb.europa.eu/about-edpb/board/members_en
COOKIES
The following section explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the website, your choices regarding cookies and further information about cookies.
GENERAL INFORMATION ABOUT COOKIES
Cookies are data files that are placed on a computer when it is used to visit a website. These cookies may be used for many purposes, including, without limitation, tracking user preferences and web pages visited while using the website. You may disable cookies using your browser’s preferences. However, some features of the website may not function properly or may operate slowly if you disable the cookies.
When you use and access the website, we may place a number of cookies files in your web browser.
We use cookies for the following purposes: to enable certain functions of the website. We use cookies to provide analytics and to store your preferences.
THIRD-PARTY COOKIES AND VENDORS
In addition to our own cookies, we may employ third party services that include various third-parties’ cookies (e.g. from Google) to report usage statistics of the Service.
LIST OF COOKIES
Necessary cookies - Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. You cannot disable them.
Currently the website may include some or all of the following cookies:
_ga (Registers a unique ID that is used to generate statistical data on how the visitor uses the website - 2 years)
_gat (Used by Google Analytics to throttle request rate -1 day)
_gid (Registers a unique ID that is used to generate statistical data on how the visitor uses the website - 1 day)
COOKIE PREFERENCES
As we use only necessary cookies, they are enabled by default.
If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please change the privacy settings of your web browser.
Please note, if you delete cookies, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
CALIFORNIA CONSUMERS
This section refers to all Users of website www.vertipay.net who are California Consumers.
California consumers have a right to knowledge, access, and deletion of their personal information under the California Consumer Privacy Act (CCPA). California consumers also have a right to opt out of the sale of their personal information by a business and a right not to be discriminated against for exercising one of their California privacy rights.
Vertipay Ltd provides notice of our privacy practices in this section of our Privacy Policy. The section includes what personal information is collected, the source of the personal information, and the purposes of use, as well as whether we disclose that personal information and if so, the categories of third parties to whom it is disclosed.
California consumers who would like to exercise your privacy rights, may make requests to legal@vertipay.net. We will ask you for information which we consider necessary to verify your identity for security and to prevent fraud. This information may include name, contact information, etc. The specific information requested may differ depending on the circumstances of your request. If you request a deletion of your personal information, please note that we may still need to retain certain information for record keeping purposes. Some of your information may also remain within our systems and other records where necessary for compliance with applicable law
CALIFORNIA DO NOT TRACK DISCLOSURE
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user.
VertiPay Ltd does not track its visitors over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.
CALIFORNIA RIGHT TO NON-DISCRIMINATION
VertiPay Ltd does not discriminate against customers who exercise their rights under applicable privacy law.
If you choose to exercise your privacy rights, you have the right to not to receive discriminatory treatment or a lesser degree of service from VertiPay Ltd.
NOTICE FOR MINORS
We do not knowingly collect personal information from minors without proper consent from a parent or а legal guardian. If you believe that we may have collected personal information from a minor without the requisite consent, please write to us at legal@vertipay.net. and we will investigate and promptly address the issue.
Minors, or their legal guardians, may change or revoke the consent choices previously made or request access to or removal of any personal information that they have provided to Us. sites by contacting us at legal@vertipay.net.
UPDATE OF PRIVACY POLICY
We occasionally may update this Privacy Policy based on any changes regarding the processing of Your personal data.
Effective date: 29.04.2021
Version: 04/29.04.2021
