This document was last updated on 9th May 2018

GlobalWebPay, General Data Protection Regulation (GDPR) and You

How will GDPR benefit you?

You currently have a legal right to access the personal information we hold on you and you can request that your information be updated and in certain instances, deleted. You can also ask us not to send you any direct marketing communications, meaning promotional offers, useful information regarding the making of payments or other marketing material aimed specifically at you.

The new regulation will give you additional rights that require us to correct or delete any errors in the information we hold about you.
You will have the right to ask us to restrict our processing of your data, and where that processing is based on your consent, you will be able to withdraw that consent. We will consider any objection you may have relating to your particular circumstances, to any of our processing activities.
You may also request a copy of the personal information we hold on you, which you previously provided to us, in a format that is suitable for sending to another organisation.
The new regulation will bring greater benefit to our customers who will have better protection of your personal information, more control and greater flexibility.

Your rights under these laws are not unqualified and in certain circumstances, such as compliance, industry regulation or law, your request may be refused.
You have the right to refer such instances to the Information Commissioner (ICO)

How do we gather and use your personal information?

We collect your personal information in a number of ways.
This begins with any interactions we have before you become a customer.

We store any relevant information obtained by third parties from the routine checks conducted before we accept you as a customer.
After registering with us you may provide us with further personal information, for example by email or telephone, which we will also store.

We then process this personal information primarily to fulfil our contractual services to you and meet our regulatory requirements. By processing we mean obtaining, recording, holding and using your data. The nature of our business means it is often necessary to use third parties to process your data and process your payments. This ensures we provide an efficient and high-quality service.

You may provide us with personal information about other people or organisations, such as the recipients of your payments. In these instances, we ask that you have their authority to provide this information to us. There are also legal, regulatory and other governance requirements that we need to comply with that require us to process your personal information.

How do we share and store your personal data?

Global Web Pay Limited (known as GlobalWebPay), as the data controller, may share your personal information with our payment partners, banks involved in the processing of payments either to or from us, or other third parties where it is relevant to services provided to you.
In addition, we may occasionally be required by law, our regulators or other regulatory authorities to report certain personal information.

We will keep your personal information for as long as we provide you with our services. We may also be obliged by our regulators in the territories in which we operate, to keep your data for longer for legal, regulatory or other governance reasons.

Sending data outside of the European Economic Area (EEA)

As we operate our payments service globally it is possible that your personal information will be transmitted to and processed in countries outside the European Economic Area, that may not provide the same level of data protection.
We will only send your data outside of the EEA if;

1. It is required in order to follow your instructions and provide our services to you
2. You request us to
3. We have to comply with a legal or regulatory duty
4. We are establishing, exercising or defending our legal rights
5. We are otherwise permitted to do so under applicable data protection laws
Where this happens, we will put in place adequate measures to ensure that your information is suitably protected when it is transferred out of Europe. We will do this by using one of the following procedures; 1. Transfer the information to a non-EEA country with privacy laws that give the same protection as the EEA
2. Put in place a contract with the recipient that means they must protect the personal information to the same standards as is required in the EEA
3. Transfer it to organisations or countries that are part of approved certification schemes or have frameworks in place such as Privacy Shield, between the EEA and the USA

Our privacy promise to you

We never sell your data
We keep your data safe and secure
You can review and change your marketing choices at any time

Changes to this policy

We may make changes to this policy from time to time as our business, regulatory environment or laws change.
We will post the latest version of this policy on our website as soon as any changes are made

Contacting us about GDPR and your personal data

If you have any questions about GDPR or your personal information, please contact us at the details available on our website. If you contact us by email you can do so by writing to: support@globalwebpay.com Please mark your email for the attention of the “Data Protection Officer”

This policy may be made available in a number of different European languages; all versions are legally binding but in the event of any inconsistency between the English Language version and a translated version, the English Language version will prevail.

The GlobalWebPay product and associated services are provided by GlobalWebPay Ltd.
("GlobalWebPay", "our" or "we") take the privacy of your personal information very seriously. All data is collected, transferred, processed and maintained in accordance with the principles contained within the Data Protection Act 1998 of the United Kingdom and the Privacy and Electronic Communications (EC Directive) Regulations 2003. This Privacy Policy describes the personal information we collect, use and disclose to enable us to operate our business in support of the services we offer. We encourage you to review this Privacy Policy.

By providing personal information to us and by dealing with us, you expressly consent to the collection, use and disclosure of your personal information in accordance with the terms set out in this Privacy Policy. If you object to your personal information being collected, used or disclosed as described in this Privacy Policy, you should not register with us as a GlobalWebPay Account Holder.

In this Privacy Policy “personal information” or “personally identifiable information” means information about you that can be attributed to you. GlobalWebPay will collect, use and disclose your personal information only in accordance with the terms of this Privacy Policy.

We may collect, use and disclose personal information as authorised by law or with your consent. Depending on the circumstances, your consent to the collection, use and disclosure of personal information may be express or implied. Express consent arises when you specifically consent to a particular dealing in your personal information. Express consent can be given orally, electronically (for example by acknowledging a check box on a webpage) or in writing. Implied consent can be inferred from the circumstances, taking into account the reasonable expectations of Account Holders and the sensitivity of the information. If GlobalWebPay needs to collect, use or disclose any information for any purpose not set out in this Privacy Policy, we will give you appropriate notification and give you the opportunity to object to or decline the collection, use, or disclosure of this information.

If you have questions or concerns regarding this Privacy Policy, you should contact the Customer Support Team, contact details are given at the end of this document.

We reserve the right to amend this Privacy Policy at any time and for any reason. When changed, we will provide notice to you on our website that it has been changed. Please check the GlobalWebPay website at https://www.globalwebpay.com/ at any time for the most current version of our Privacy Policy.

Any amendments to this Privacy Policy will be effective from the time of posting, and by continuing to use our service; you expressly consent to any such amendments. If you disagree with any amendments, you may close your Account at any time.

Information Required

To open and maintain a GlobalWebPay Account, you must provide your name, address, phone number, date of birth, e-mail address and we may also ask you to provide government issued/photo identification, credit card, debit card or bank account information. We also ask you to choose a security question to answer (such as your first school or your city of birth) and to provide a password. This information is required to ensure that we can:
 

• Process transactions;
• Issue a new password if you forget or lose your password;
• Protect you, GlobalWebPay and our other Account Holders and Merchants against identity theft, credit card fraud and bank account fraud; and
• Contact you should the need arise in administering your Account.

Transaction Information

Transaction information relates to any information required to send or request a payment. This may include: the amount of the transaction, the type of transaction, the bank and bank account details, e-mail address, phone number of the payee or beneficiary involved in the transaction.

We may retain a third party’s contact details, provided that and so far as they are necessary for the provision of our services or the fulfilment of our legal obligations.

For fraud and/or security purposes, we may retain your personal information, including transaction information for all of your transactions through GlobalWebPay, for a number of years even after your Account is closed.

We also collect the Internet address (IP address) of the computer or device you use to access your GlobalWebPay Account, in order to help detect possible instances of unauthorised transactions.

Information About You Provided by Third Parties

In order to protect all our Account Holders against potential fraud, we verify the personal information that you provide with third party verification service providers. In the course of such verification, we may also receive personal information about you from such service providers. In particular, if you register a debit or credit card or bank account with GlobalWebPay, we will, wherever possible, use card authorisation, authentication and fraud screening services to verify that your card information and address matches the information that you supplied to GlobalWebPay, and that the card has not been reported as lost or stolen.

If you incur a debt to GlobalWebPay, we may conduct a credit check on you by obtaining additional information about you from a credit reference agency, to the extent permitted by law. GlobalWebPay, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account, and reserves the right to close an Account based on information obtained during this credit review process.

Web Site Information

Because of the way that World Wide Web communication standards work, when you arrive at or leave the GlobalWebPay website, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the GlobalWebPay site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our Account Holders' behaviour and preferences, to develop and improve our services to you, and to manage the load on our servers. We do not track the Web sites that you visit before or after you leave the GlobalWebPay site.

Cookie Policy

We may store information about you using cookies. "Cookies" are small data files that reside on your computer and allow us to recognise you as a GlobalWebPay customer if you return to the GlobalWebPay site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your Account by entering your e-mail address and password. These cookies allow us to recognise you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

Most browsers allow you to turn off cookies. If you want to know how to do this please look at the help menu on your browser. However, switching off cookies may severely restrict your use of the GlobalWebPay and many other sites.

As you may be aware, recent legislation requires websites to gain visitors' consent to use certain cookies. We're working to implement appropriate changes to our website as soon as possible. We use cookies to help provide you with the best possible online experience. By using this site, you agree that we may store and access cookies on your device.

For independent advice on how to deal with cookies go to http://www.aboutcookies.org

Customer Service Correspondence and Phone Calls

If you send us correspondence, including e-mails and faxes, we retain such information in the records of your Account. We will also retain customer service correspondence and other correspondence from GlobalWebPay to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our Terms of Use. In addition, any phone calls made to or from us may be monitored and/or recorded for quality assurance purposes, and security and fraud detection purposes.

Questionnaires, Surveys and Profile Data

From time to time, we may offer you optional questionnaires and surveys for such purposes as collecting demographic information, assessing our Account Holder’s interests and needs and evaluating Account Holder’s experience with the GlobalWebPay service. If we collect personal information from you in these questionnaires and surveys, you will be given notice of how the information will be used prior to your participation in the survey or questionnaire. You can opt-out of receiving information on questionnaires and/or surveys by emailing us at support@globalwebpay.com quoting your account name and email address.

Information Required

Except as otherwise provided in this Privacy Policy, we will obtain your explicit or implied consent to use your personal information in a particular manner. Set out below are certain circumstances where we may use your personal information without obtaining your further consent. These are:
 

• To verify your identity and financial information;
• To process your transactions, including using your bank account information to obtain payments owing to us;
• To analyse your personal information and transaction history to assist us in developing and enhancing our services and our website, to conduct market analysis and strategic planning and to determine your eligibility to receive offers for special features, promotions, and products
• To use your personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose. For example, if you send us an e-mail with a question or comment, we will use your e-mail address to respond to you. Further, we may store your e-mail and e-mail address and a copy of our response for future reference;
• To troubleshoot any problems.

We give access to your personal information only to those employees who require it to provide our services to you. 

Internet Address Information

We use IP addresses, browser types and access times to analyse trends, administer the site, improve site performance, gather broad demographic information for aggregate use, and to prevent fraud.

Disclosure to Third Parties

GlobalWebPay will not sell or rent any of your personal information to third parties.

GlobalWebPay will not share any of your personal information with third parties except in the limited circumstances described below, as permitted by applicable law, or with your express permission. These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.
 

• We share information with companies that help us process the transactions you request and protect transactions from fraud, such as sharing your debit card number with a service that screens for lost and stolen card numbers. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including debt collection agencies.
• In order to assist us in conducting or co-operating in investigations of fraud or other illegal activity, or in order to assist us in investigating suspected violations of our Terms of Use, we may disclose personal information to third parties where we believe it is reasonable and appropriate to do so.
• We disclose information in response to a witness summons, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including witness summons from private parties in a civil action.
• We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
• For identity validation and verification purposes, the following information may be provided to Banks to or from whom you transfer funds: name, Account number, jurisdiction, postal code, e-mail address, and/or IP address.
• We may disclose information to service providers who manage various marketing or development programs on our behalf. Your personal information will be provided under a strict code of confidentiality. If we transfer your information to a service provider in another country, we will make sure that the service provider agrees to apply the same levels of protection as we are required to apply to information held in the UK and to use your information only for the purpose of providing the service to us. These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information was shared.
• As with any other business, it is possible that GlobalWebPay in the future could amalgamate or merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the personal information maintained by GlobalWebPay, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section 3 above.

Customer Contact

We communicate with Account Holders on a regular basis via e-mail and, in the future, may use “live chat” or a similar service, to provide requested services, and we may also communicate by phone to resolve customer complaints, investigate suspicious transactions or to inform you of changes to our service or accept instructions regarding your Account. We use your e-mail address to confirm your opening of a GlobalWebPay Account, to send you notice of payments that you send or receive through your Account, to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, Account Holders cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.

Upon opening a GlobalWebPay Account, every Account Holder will receive an email confirming their successful registration.

Marketing Communications

We use your e-mail address to send you various types of communications that you can control, including marketing communications, surveys and questionnaires, and notice of special promotions from GlobalWebPay or its carefully selected business partners. Such promotions will relate to similar products and services to those offered by GlobalWebPay. Out of respect for your privacy, you can choose not to receive these types of communications from us. An explanation of how to do this will be contained within each promotional email that you receive. By agreeing to GlobalWebPay’s Terms of Use you will also be indicating your consent to receiving promotional emails.

By accepting this Privacy Policy, you agree to only use any personal information you may have obtained from the use of our services for GlobalWebPay related communications, and not for any unsolicited commercial communications.

Information Security and Protection

GlobalWebPay is committed to handling your personal information with high standards of information security. We do not store your debit card information. Your bank account information (if collected) is only stored on computers that are not connected to the Internet. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard your non-public personal information. We test our security systems regularly and also contract with outside companies to audit and test our security systems and processes.

We protect your information from error, loss, and unauthorised access. Our employees who have access to your information are made aware of how to keep it confidential. Each employee must sign an agreement stating that maintaining confidentiality is a condition of employment with GlobalWebPay. All of your personal information is collected, used, and disclosed for business purposes only.

Your Responsibility

The security of your GlobalWebPay Account also relies on your protection of your GlobalWebPay security identification. You may not share your password with anyone. GlobalWebPay will never ask you to send your password to us in an e-mail, although we may ask you to enter this and other personal information on the GlobalWebPay website, which will always have a URL beginning withhttps://www.globalwebpay.com/.

Phishing

Any e-mail or other communication asking you to provide personal information via email, or linking to a website with a URL that does not begin with https://www.globalwebpay.com/ should be treated as unauthorised and suspicious and should be reported to GlobalWebPay immediately. If you do share your password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your Account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your security identification or password, please change it immediately by logging in to your Account athttps://www.globalwebpay.com/ and updating your password on the “Personal Settings” page, and also contact us right away as described in Section 9 below.

You can review the personal information you provided us and make any desired changes to such information, or to the settings for your GlobalWebPay Account, at any time by logging in to your Account on the GlobalWebPay Web site.

If you close your GlobalWebPay Account, we will mark your Account in our database as "Closed," but will keep your Account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their Account and opening a new Account.

However, if you close your Account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.

At your request, GlobalWebPay will also share with you where your personal information has been stored, what personal information GlobalWebPay has about you, for what purposes GlobalWebPay uses it for and with whom it has been shared.

If you have any questions about this privacy statement, GlobalWebPay's information practices, or your dealings with GlobalWebPay, you can contact us in a number of ways:
 

• via e-mail at support@globalwebpay.com. Email support is also available outside office hours (see below), including weekends.
• you can call our Customer Support Team directly on +44 (0) 20 7233 9595 during office hours (see below)
• When you contact the Support team on this number please have the following information readily available in addition to your full name:

          - Your Account number,
          - Your email address,
          - Be prepared to explain your question, enquiry or complaint.

Our Customer Support Team is available during office hours 09:00 to 17:00 GMT Monday to Friday.

If you want a copy of these Terms of Use or of any of the other 'legal' documents' that appear on this website you should send an email with the words "Policy documents" in the subject line to support@globalwebpay.com

GlobalWebPay Limited “GlobalWebPay” (UK Company Registration number, 07321803) has its registered office at 1 Forstal Road, Aylesford, Kent. ME20 7AU. Global Web Pay Limited is authorised by the Financial Conduct Authority (FCA) under the Payment Service Regulations, 2009 for the provision of payment services. FCA Registration Number FRN 631844.