Privacy Policy
Last updated: March 5, 2023
Throughout this Privacy Policy, "You" may refer to a Visitor of our website, a Merchant who intends to use or is using our products or services, including any shareholders, beneficial owners, principals, directors, and staff members accessing our website, or a Customer of a Merchant. "Visitor" may include "Merchant" and/or "Customer" where appropriate, and we will do our best to clarify who we are referring to at various points in this Privacy Policy.
Data Collection and Processing
As a Visitor, Merchant or Customer on our website, stipendum.com (hereinafter referred to as the "Website"), you may provide us with information and documentation via the Application or Contact Us forms. This information may include your name, surname, email address, telephone number, and company name, among other details. As a Merchant, you may provide us with additional information and documentation in order to enter into an agreement with us. This information may include, but is not limited to, your name, date of birth, physical address, telephone number, email address, company name, company number, current position, previous employment history, education, passport or ID data, payment account number, and beneficial ownership details. If you are a Visitor applying for a job vacancy, you may provide us with information including your name, date of birth, physical address, telephone number, email address, company name, current position, previous employment history, education, and other relevant details.
In the event that you contact us, we may record our correspondence and/or telephone call. This record may include your name, surname, email address, telephone number, and any other personal information you disclose during the communication.
If you are a Merchant with access to our Client Interface, we may collect details of your visits, including location data, weblogs, communication data, and the resources you access. If you are a Customer using our payment page or a Merchant transferring funds, we may collect your personal data, including your name, surname, email address, telephone number, payment instrument details (such as card number, expiry date, CVC/CVV code, credit/financial institution and/or issuer details), and information about the purchased products or services, including location and time of the transaction. We may also receive information about you from other sources, including our business partners, service providers, subcontractors, card organisations, payment service providers, credit reference agencies, and other third parties, as well as publicly available information.
Additional Data Collection
In addition to personal information, we may collect non-identifying data about you as a user of our website. This non-personal data may include:
- Browser and device information, such as IP address, operating system, and browser type. This statistical data provides insight into the browsing habits and patterns of our website users, without revealing individual identities;
- Cookie information, including anonymous traffic data such as time spent on the website, pages visited, and language preferences;
- Company details, such as the name of the organization, as well as their products and services offered and jurisdiction.
Personal Data Usage
At STIPENDUM, we take your privacy seriously and use your personal data solely for the purpose of providing our services/products to you. As a Merchant, we use your personal data to conclude contracts and carry out our contractual obligations. In this regard, we rely on the contract entered into by you and STIPENDUM as the valid ground for processing your personal data. As a Customer, we use your personal data to enable you to use our services/products, such as making payments on the Merchant's website. In this regard, we rely on the legitimate interests pursued by us.
We also have a legal obligation to prevent fraud, money laundering, terrorism financing, and to comply with other legal obligations. To fulfill this obligation, we process your personal data. In this regard, we rely on the necessity to comply with legal obligations as the valid ground for processing your personal data. We may also process your personal data for various marketing activities, and in this regard, we rely on your consent as the valid ground for processing your personal data.
Examples of how we may use your personal data include providing you with information, products or services requested from us, notifying you about changes to our products or services, processing transactions/payments, ensuring that content from our website is presented in the most effective manner, verifying your identity for legal/regulatory compliance purposes, conducting monitoring against any possible fraud, money laundering, terrorism financing or crime risks, responding to your inquiries and providing customer support, conducting market research and carrying out marketing activities.
At STIPENDUM, we are committed to ensuring the safety and security of your personal data and take all necessary measures to protect it from unauthorized access, use, or disclosure.
Retention of Personal Data
We understand the importance of keeping your personal data secure and will only retain it for as long as necessary to fulfil the purposes outlined in this Privacy Policy. In certain circumstances, we may be required to keep your personal data for a longer period of time to comply with legal or regulatory obligations.
We may need to retain your personal data for legal or regulatory reasons such as complying with anti-money laundering and counter-terrorism financing laws or investigating potential fraud. In these cases, we will retain your personal data for the minimum period necessary to meet our legal obligations.
Even if you no longer use our services as a Merchant or a Customer, we may need to retain some of your personal data to fulfil our legal obligations. Rest assured that we will only retain the minimum amount of personal data necessary to meet these obligations.
Service Usage Limitation by Minors
The usage of our services and products is intended exclusively for individuals above the age of sixteen. As such, we respectfully request that any individual falling below this age refrain from divulging their personal information to us.
Disclosure of Personal Data
Under certain circumstances, we may need to disclose the personal data we have collected about you to various recipients, including:
- Third-party financial institutions: This includes card organizations, payment systems, and credit/financial institutions where you maintain your payment account or any other type of account as a merchant or customer;
- Credit reference agencies: We may share your personal data with credit reference agencies to conduct credit checks and obtain credit reports;
- Third-party service providers: We disclose personal data to service providers only when it is necessary to ensure the provision of our services, including but not limited to processing payments/transactions;
- Third parties in relation to the transfer of business: If we sell any business or assets or merge with another business entity, it may be necessary to disclose personal data to the prospective business owners or partners;
- Our merchants: We may disclose certain personal data that you have provided to us or that we have received about you as a customer to the relevant merchants in order to assist them in carrying out their legal obligations or obligations towards you as their customer;
- Third parties in relation to a legal obligation or if we are permitted to do so by law: In certain circumstances, we may be under an obligation to disclose or share your personal data with auditors, regulatory authorities, or law enforcement bodies to comply with a legal obligation. We may also disclose personal data if it is permitted by law to enforce or apply the WEBSITE TERMS OF USE or other agreements or to protect our rights, property, customers, or others;
- Third parties in relation to a legal obligation or if we are permitted to do so by law: In certain circumstances, we may be under an obligation to disclose or share your personal data with auditors, regulatory authorities, or law enforcement bodies to comply with a legal obligation. We may also disclose personal data if it is permitted by law to enforce or apply the WEBSITE TERMS OF USE or other agreements or to protect our rights, property, customers, or others.
Please note that your personal data may be transferred and processed outside the European Economic Area (EEA), and it may be processed by staff operating outside the EEA who work for us or one of our service providers. To ensure that your personal data is treated in a secure manner and in accordance with this Privacy Policy.
Your Rights
You have various rights with respect to the manner in which we handle your personal data:
- You have the right to access and obtain information about the personal data that we process. You may do so by logging into your Client Interface account or by contacting us at legal@stipendum.com;
- You have the right to correct any inaccuracies in your personal data that we hold. You may do so by logging into your Client Interface account or by contacting us at legal@stipendum.com;
- You have the right to object to the processing of your personal data;
- You have the right to withdraw your consent for the processing of your personal data for marketing purposes. We will inform you in advance (prior to collecting your data) if we intend to use your data for such purposes or if we plan to disclose your information to any third party for such purposes;
- You may also request the deletion of your personal data or that we cease processing it. Please note that this right may be subject to certain exceptions. Specifically, where we are legally required to retain your personal data, we may be unable to fulfill your request, and we will inform you accordingly;
- You may also request that we provide you with your personal data or transmit it directly to another controller, provided that the processing of your personal data by us was based on your consent or was necessary for the performance of a contract, and where it is technically feasible;
- You have the right to file a complaint with the Information Commissioner's Office if you believe that we have failed to comply with the requirements of the General Data Protection Regulation regarding your personal data.
Security
We assure You that any information that You provide to us is securely stored on our servers, and we implement suitable organizational, technical, and administrative measures to safeguard Your personal data.
To prevent unauthorized access, we employ rigorous procedures and security features upon receipt of Your information. Furthermore, we follow the recommendations of the Payment Card Industry Security Standards Council by utilizing Transport Layer encryption, specifically TLS 1.2, in conjunction with application layer AES algorithm and 256-bit key length to protect customer card details.
Nonetheless, it is important to note that no internet transmission is entirely secure and no storage system can guarantee complete security. If You have reason to suspect that Your interaction with us is no longer secure, kindly notify us without delay.
Privacy Policy Changes
We reserve the right to modify or revise this Privacy Policy as needed. Any alterations made to this Privacy Policy will be duly posted on the Website, and will come into effect from the date of posting. In order to keep You apprised of any changes to this Privacy Policy, we may provide notifications of such modifications by posting them on our Website,