PRIVACY POLICY


Last updated on 10/09/2019
BennuPay (“BennuPay”, “We”, “Our”) and its partners offer their merchants products and services involving electronic payment transactions. Our goal is to enable merchants and customers worldwide to handle electronic transactions securely, safely and smoothly. Security and the protection of personal data are the most important aspects in handling and processing of payments.
This Privacy Policy describes the types of Personal Data we collect through our products and merchant services (“Services”) and online, which include our website www.Bennupay.com (our “Site”). This Policy also describes how we utilize personal data, with whom we share it, your rights, and how you can contact us about our privacy practices. This Policy is related only to BennuPay and does not apply to third-party websites, products, or services, even if they link to our Services or Site, and you should consider the privacy policies of those third-parties carefully.

I. PROCESSING OF PERSONAL DATA AND OTHER DATA BY BENNUPAY DURING VISITS OF OUR WEBSITE
Your Merchant Processing Agreement or Agency Agreement with BennuPay should explain how we share your Personal Data, and if you have questions about how it could be shared, then you should send your questions to our support team (support@Bennupay.com)

1.Information we automatically collect when you access our website
No personal data will be collected, since the IP address is truncated before collection.

2a. Personal Data we collect from and about you
We offer a contact form on our website. BennuPay will store the personal data provided by you when you send the completed contact form (e.g. name, address, telephone number, e-mail address, skype name, country, who your current Services provider is, the industry your business operates in, how you intend to take card payments and the amount you will be processing) in its Customer Relationship Management System („CRM System“). BennuPay will use such personal data for the following reasons:
to respond to your contact request;
in anonymized form to support our internal business objectives, namely data analyses, revisions, the development of new products, improvement of this internet presence, improvement of our services, detection of usage trends and determination of the effectiveness of our advertising campaigns;
in order to prevent and identify abuse or fraud.
The data collected via the contact form will not be forwarded to third parties, unless where necessary in order to respond to your contact request.
If you are a Customer, when you make payments or conduct transactions through a BennuPay website or application, we may receive your transaction information. Depending on how the Merchant or Agent implements our Services, we may receive this information directly from you, or from the Merchant or Agent. The information that we collect will include payment method information (such as credit or debit card information, purchase amount, date of purchase, and payment method). Different payment methods may require the collection of different categories of information.

2b. Information that we collect automatically on our Site.
Our Site use cookies and other technologies to function effectively. These technologies record information about your use of our Site, including:
• Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Site you are visiting;
• Usage data, such as time spent on the Site, pages visited, links clicked, language preferences, and the pages that led or referred you to our Site.
To learn more about the cookies that may be served through our Site and how You can control our use of cookies and third-party analytics, please see our Cookie Policy.
3. How We Use Personal Data
a. Our products and services.
We take all measures to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our Merchants and Agents to comply with our financial regulatory and other legal obligations. We also use Personal Data to complete payment transactions and to provide payment-related services to our Users.
b. Marketing and events-related communications.
We may send you our Newsletter about BennuPay products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements imposed by applicable law.
4. How We Disclose Personal Data.
BennuPay does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities.
a. BennuPay - We share Personal Data with other entities in order to provide our Services and for internal administration purposes.
b. Service providers - We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorise such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf.
c. Business partners. We share Personal Data with third party business partners when this is necessary to provide our Services to our Merchants. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment method providers (such as credit card networks) when we provide payment processing services.
d. We share data with parties directly authorised by A Merchant and Agent to receive Personal Data. The use of Personal Data by an authorised third party is subject to the third party’s privacy policy.
e. Compliance and harm prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of BennuPay, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
II. DATA SUBJECTS RIGHTS
Under GDPR, visitors as data subjects have certain rights in particular the right to access, correct, update, or request deletion of your personal data that we store about you.
If you wish to exercise any of these rights, you can do so at any time by contacting us via email.
You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us via email.
Similarly, if we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact us at the above e-mail address.

III.SECURITY AND DATA RETENTION
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. In order to protect Personal Data within our organisation against unauthorised access, destruction, loss, alteration or misuse. BennuPay uses firewalls in order to prevent unauthorised access to servers.
We store your personal data for as long as it is needed to fulfil the purpose for which they were collected notwithstanding any statutory retention obligations, in particular according to tax or accounting law.

IV. TRANSFER OF YOUR PERSONAL DATA
Your personal data will be used only to the extent necessary to achieve the purposes named in this data privacy statement. Your data will be forwarded to third parties, if at all, only within the limits of statutory regulations. Personal data will be forwarded to government institutions and authorities only within the limits of compulsory national legal provisions, or if those data must be forwarded for legal or criminal prosecution because abusive or fraudulent actions have been committed. Forwarding for any other purpose, especially for address trading, is excluded.
We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy.

V. COOKIES
Cookies are text files containing small amounts of information, sent by your web browser by a website you visit, which your computer downloads. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies do lots of different jobs:
Help us understand how this website is being used
Make it easier for you to navigate between pages efficiently
Remember your preferences
Generally improving your browsing experience
Ensuring the marketing you see online is more relevant to you and your interests
 However, please be aware that restricting cookies may affect the functionality of this website.


Strictly Necessary Cookies
These cookies are essential, as they enable you to move around the site and use its features - such as accessing secure areas. Without these cookies, services you've asked for can't be provided. These cookies don't gather information about you for the purposes of marketing, or remembering where you've been on the internet.
Performance Cookies
These cookies collect information about how you use a website. For example, which pages you go to most often, and whether you get error messages from certain pages. These cookies don't gather information that identifies you. All information these cookies collect is anonymous and is only used to improve how a website works.
Functionality Cookies
These cookies allow a website to remember choices you make (such as your user name, language or the region you're in) and tailor the website to provide enhanced features and content for you. These cookies can also be used to remember changes you've made to text size, font and other parts of pages that you can customize. Without these cookies, a website cannot remember choices you've previously made, or personalize your browsing experience.
Cookies set prior to you changing your settings may still be on your computer. You can remove them using your browser settings.

VI. CHILDREN PROTECTION
The provider does not solicit or knowingly accept information from persons under the age of 18 years old. Our website is not designed with the intent to attract or encourage viewing by children.

V. UPDATES TO THIS PRIVACY POLICY AND NOTIFICATIONS.
We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.

VI. CONTACT US
If You have any questions or complaints about this Privacy Policy, please contact us electronically or send physical mail to: compliance@bennupay.com.