Privacy Policy

Introduction
1.1. Safe2Pay Ltd (“Safe2Pay”) values your privacy and takes it seriously. This Privacy Notice outlines how Safe2Pay collects and processes your data as a data controller when you interact, apply, or establish relationships with us as a customer or partner, or when you use our services and website.
1.2. This Notice explains our current policies and dedication to protecting your data. We strive to collect and process only the data essential for our relationship with potential or current customers, partners, and users/visitors of our websites, ensuring that we provide services and information for specific, legitimate purposes.

Safe2Pay is committed to safeguarding the privacy and confidentiality of the information we manage. We ensure the proper use and security of personal data in line with applicable data protection laws, such as the EU Regulation 2016/679 (GDPR), where applicable.
The most recent version of our Privacy Notice is available on our website’s homepage at www.safe2pay.co.uk. Please review it carefully, as it describes how we collect, use, share, and safeguard your personal data.

Scope and General Provisions
2.1. This Notice complements the relevant Terms and Conditions associated with Safe2Pay’s services/products and also applies to the use of our websites and online systems. Safe2Pay encompasses a network of businesses operating across multiple markets worldwide. In this context, “we” or “us” refers to the Safe2Pay entity responsible for your data processing.
2.2. The Notice applies to personal data processed by Safe2Pay as a data controller. It includes details about:

• The personal data we collect;
• How we use personal data;
• The entities with whom we may share personal data; and
• Your rights concerning your data.
  2.3. This Notice addresses individuals (“data subjects”) in the following scenarios involving Safe2Pay:
• Directors, representatives, shareholders, officers, employees, or individuals linked to legal entities or who are current, former, or prospective customers.
• Representatives of legal entities or individuals applying for Safe2Pay services/products, or users of our services, website, or systems.
• End users utilizing our payment initiation services to facilitate payments from their bank accounts.
  2.4. “Personal Data” refers to information that identifies or could identify you (e.g., name, address, ID number). “Processing” refers to actions such as collecting, handling, storing, or protecting this data.
  2.5. Safe2Pay’s website may link to third-party websites or services, which operate under different data protection policies. Before using those services, ensure their policies meet your expectations. Safe2Pay bears no responsibility for third-party data practices.

Required Personal Data
3.1. Establishing and maintaining legal business relationships and providing services requires specific personal data. You must provide personal data for the following reasons:

• To comply with legal obligations, including anti-money laundering (AML) laws and other regulations that mandate identity verification and due diligence.
• To fulfill contractual requirements, such as entering into agreements or executing transactions.
• To support Safe2Pay’s legitimate interests, such as ensuring security, managing access control, and maintaining quality communication.
  3.2. Personal data is required both during the establishment and throughout the contractual relationship. Failure to provide the necessary data may prevent us from forming or continuing a business relationship.
  3.3. In many cases, Safe2Pay acts as a processor of personal data for merchants/service providers who are the data controllers. For example:
• When processing card or online payments, we handle transaction and personal details required for completing payments on behalf of merchants. Refer to the merchant’s privacy policy for more information.
• When providing payment initiation services, we connect to your bank to facilitate payments, acting as a processor for the merchant or service provider.

Collection and Use of Personal Data
How We Collect Data
4.1. We gather personal data from the following sources:

• Data you provide: Information submitted via application forms, emails, or communication channels during account setup or the course of a business relationship.
• Data collected through service usage: Payment and transaction details, technical and device data, and data linked to payment initiation services, including authorizations and consents.
• Third-party data: Data obtained lawfully from external entities like service providers, regulatory bodies, or other Safe2Pay group companies.
• Public data: Information available in public databases, registries, or the media.
  4.2. While most data comes directly from you, additional data may be generated or obtained through other means to enhance our services.

Types of Data We Collect
4.3. The data we collect depends on your interaction with Safe2Pay and may include:

• Personal details: Name, birthdate, language, public function status (PEPs), etc.
• Contact information: Work/home address, email, phone numbers.
• Identity documents: Passport, ID card, tax information.
• Financial information: Income, assets, bank details, professional status, etc.
• Authentication data: Login credentials, signature samples.
• Transaction data: Payment details, location, amounts, and merchant information.
• Technical and location data: IP addresses, device details, and more.
• Due diligence data: Results of AML checks, fraud prevention measures, etc.
• Media records: CCTV footage at Safe2Pay offices.
• Consents and authorizations: Permissions granted for specific processing activities.

Purpose of Data Processing
4.4. We process your data in line with the principle of data minimization, ensuring that only necessary data is used for lawful purposes, such as:

• Verifying your identity.
• Providing and managing services.
• Executing transactions and fulfilling contractual obligations.
• Performing anti-money laundering checks and fraud prevention.
• Ensuring security, risk management, and business continuity.
• Conducting internal analysis, maintaining communication, and improving services.
• Complying with legal and regulatory requirements.

Legal Bases – Lawful Reasons for Processing
4.5. When handling your personal data, we will rely on one of the legal grounds for processing outlined below. Depending on the specific purpose for which your data is being used, multiple legal bases may apply.
4.5.1. Contract Formation and Fulfillment
This applies when processing your personal data is necessary to establish a service contract with you and/or to fulfill our obligations under an agreement made with Customers. This also includes processing activities conducted during the application process to complete the approval steps required for onboarding a prospective Customer and initiating a contract.
4.5.2. Compliance with Legal Obligations or Public Interest
This applies when processing is required to fulfill legal obligations. Safe2Pay is subject to various statutory and regulatory requirements, including AML (Anti-Money Laundering) laws and payment service regulations. Additionally, we must adhere to the directives and policies of regulatory authorities overseeing Safe2Pay’s operations. Processing may involve identity verification, preventing fraud and money laundering, adhering to tax and record-keeping obligations, managing risk, and providing necessary information to authorities, public bodies, or law enforcement agencies.
4.5.3. Legitimate Interests
We may process personal data when necessary to pursue legitimate business or commercial interests, provided these do not override your rights, interests, or fundamental freedoms.
4.5.4. Your Consent
In specific situations, we may request your explicit consent to process your personal data for defined purposes. Your information will only be processed in this manner if you provide your consent, which you may withdraw at any time. Revoking consent does not affect the legality of processing conducted prior to withdrawal.

Information Collection
Safe2Pay may gather and process the following categories of personal data:

• Identification details: such as your name, surname, nationality, and other identifying information.
• Contact details: including your email address, phone number, and physical address.
• Transaction details: such as the services used, transaction records, and related data.

Use of Data
Collected information will be utilized by Safe2Pay to:

• Deliver the requested services and provide necessary support.
• Ensure compliance with applicable legal and regulatory standards.
• Enhance and optimize the quality of our services.

Data Sharing
Safe2Pay may share your personal data with trusted third parties, such as:

• Regulatory agencies, supervisory bodies, and law enforcement.
• Service providers and partners assisting in the delivery of our services.
• Other entities within the Safe2Pay corporate group.

Data Retention
Safe2Pay retains your personal data only for as long as necessary to achieve the purposes for which it was collected and to comply with relevant legal, regulatory, or contractual requirements.

Your Rights
You are entitled to the following rights regarding the personal data held by Safe2Pay:

• Access and correction of your data.
• Requesting deletion or restriction of processing.
• Withdrawing consent where applicable.

Automated Decision-Making and Profiling
7.1. Automated decision-making involves making decisions based on automated data processing without human involvement. Safe2Pay does not generally rely on such methods in establishing or managing business relationships.
7.2. However, we may use automated processes for specific tasks, such as fraud detection. This could include evaluating accounts or payment instruments to identify potential fraudulent activity, unauthorized use, or unusual patterns. If risks are identified, Safe2Pay may take action, such as freezing accounts or blocking access.

Website Data Collection – Cookies and IP Addresses
8.1. Safe2Pay’s website includes forms for visitors to submit information. Data submitted through these forms will be used according to our Privacy Notice. For example, CV submissions will be assessed for potential job matches if consent is provided.
8.2. Cookies and similar technologies may automatically collect certain data when you access our websites or online platforms, such as device type, browser details, or operating system. This data helps improve security, usability, and the effectiveness of marketing campaigns. For more information, please refer to our Cookie Notice.
8.3. IP addresses may be collected for security, diagnostic purposes, or fraud prevention. These addresses help us monitor and manage website usage trends.

Data Security
9.1. Safe2Pay implements robust internal policies and security measures to protect personal data from unauthorized access, misuse, or destruction. These include encryption, secure servers, and controlled access.
9.2. However, data transmission over the internet carries inherent risks, and security cannot be guaranteed.
9.3. Users are responsible for safeguarding their authentication credentials to access our resources and are encouraged to follow the security tips provided on our website.

Exercising Your Rights
10.1. You may exercise your rights by contacting our Data Protection Officer (DPO) using the details provided. Requests must be clear, comprehensive, and submitted in English. Identification verification may be required.
10.2. Most requests will be handled within one month, although complex requests may require additional time. We will inform you of any delays or extensions as needed.

Right to Submit a Complaint
10.7. If you have concerns regarding the processing of your personal data or how your rights have been handled, please contact our data protection team directly using the details provided below or complete and submit the relevant form available on our website: www.safe2pay.co.uk. We will promptly investigate your complaint and provide a response.
10.8. Complaints must be written in English, be clear and concise, and provide sufficient details about the issue. We may be unable to process complaints that are unclear, incomplete, or submitted in other languages.
10.9. If you feel that your complaint has not been adequately addressed by us, you may escalate the issue by filing a complaint with the relevant data protection supervisory authority in your jurisdiction (refer to the country-specific privacy terms for details). For those exercising rights under the GDPR, complaints can be submitted to the Commissioner for Personal Data Protection. More information is available on the Commissioner’s official website: https://www.dataprotection.gov.cy/.

How to Contact Us
Safe2Pay has designated a Data Protection Officer (DPO) based at its headquarters to address any questions or concerns. You can contact the DPO using the details below:

Data Protection Officer
Safe2Pay
125 Georgiou Griva Digeni, Limassol, 3101, Cyprus
Email: dpo@safe2pay.co.uk

Your Responsibilities
12.1. You are responsible for ensuring that any information you provide to Safe2Pay about yourself or on your behalf is accurate, complete, and up to date. Notify us of any changes to your information as soon as possible.
12.2. If you submit information about another individual, you are required to direct them to this Privacy Notice and confirm that they agree to the processing of their data as outlined in this document.

Privacy Notice Updates
13.1. We may revise this Privacy Notice periodically. Any updates will be made available on our website at www.safe2pay.co.uk, along with the date of the latest revision. We will inform you about significant changes by displaying the updated version on our website.
13.2. Depending on the applicable data protection laws in the country of Safe2Pay’s local operations, additional rules may apply. These country-specific terms, if applicable, take precedence over the general terms outlined in this Privacy Notice. Updates to country-specific terms will be handled in the same way as revisions to this Privacy Notice.
13.3. We encourage you to regularly check our website to review the most current version of our Privacy Notice.