Privacy Policy

1. DATA COLLECTION

How We Collect. We collect, receive, and process Personal Data about you through:

• Your interaction with us, our Sites, our mobile application, or our Services; 
• Our Customers, who provide us with Customer Data and in some cases, Payee Data; 
• Third-party services and providers, such as business partners, credit bureaus, social media tools, analytics and other publicly available sources; and
• Events we organize or take part in, and other business initiatives (including partner promotions, communications, and events).  

What We Collect. We collect, receive, and process the following Personal Data about you:

Prospect Data: 

• Website usage information: technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, geolocation  and language settings used), connectivity data, activity logs, session recordings, and the cookies and pixels installed or utilized on our Sites or your device; 
• Prospect account information: contact and business details (full name, email address, company name and phone number)  of our prospective customers and partners, which may also contain the details of their relevant internal focal persons; our communications with such Prospects (correspondences, call and video recordings and transcriptions, and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement.

Customer User Data: 

• Account login information: e-mail address and, when applicable, hashed password or other information used for authentication and access control;
• Profile and contact information: full name, title, company name, e-mail and phone number, profile picture, social media accounts, role, and additional information and media submitted by Customer’s Users or their organization;
• Platform usage information: technical usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, geolocation and language settings used), connectivity data, activity logs, session recordings, and the cookies installed or utilized on the Customer’s User’s device; and
• Direct interactions and communications with us: including recordings and transcripts of your calls and correspondence with us, e.g. for user enablement, support and training purposes. 
• Identification Information: Supplemental documentation may be required by PAYMENT BOOK to verify the identity of Customer’s directors, officers, or owners (who may be Customer’s Users), such as date of birth, address, a copy of a government-issued identification card, personal bank statements or other documentation serving as proof of identity or valid address. This includes any additional data you choose to provide to us directly through our Know Your Customer (“KYC”) process to comply with legal, regulatory, and other compliance-related requirements. To the extent that any of the foregoing solely relates to a non-human entity, we will not regard it as personal data, and this Privacy Policy will not apply to it.

Supplier Data:

• Account login information: e-mail address and, when applicable, hashed password or other information used for authentication and access control.
• Profile and contact information: full name, title, company name, e-mail and phone number, profile picture, role, department, and additional information and media submitted by Supplier Staff or their organization. When the supplier is a legal entity, we collect some information on contact persons. When the supplier’s data includes individual’s Personal Data, we also collect: social media accounts, field of occupation, bank and payment details, other information a user decides to share;
• Platform usage information: technical usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, geolocation and language settings used), connectivity data, activity logs, session recordings, and the cookies installed or utilized on the Payee User’s device.

Payee Data: 

• Account login information: e-mail address and, when applicable, hashed password or other information used for authentication and access control;
• Profile and contact information: full name, title, company name, email and phone number, profile picture, and additional information and media submitted by Payee Users or their organization;
• Payment information: Payee User name, email address, physical addresses, phone number, VAT ID, Social Security Numbers or EU Tax Identification Number, bank account number, IBAN, SWIFT code (or alternatively, account details at payment processing services such as PayPal, where applicable) and payment preferences. Supplemental documentation may be required by the Customers, such as a copy of Payee User’s government-issued identification card, personal bank statements or other documentation serving as proof of identity or valid address. This includes any additional data you choose to provide to us directly, provided to us by the relevant Customer, banks, payment processing services, your representative, or that we may require in order to properly process your payment and in order to comply with legal, regulatory, and other compliance-related requirements. To the extent that any of the foregoing solely relates to a non-human entity, we will not regard it as personal data, and this Privacy Policy will not apply to it;
• Platform usage information: technical usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, geolocation and language settings used), connectivity data, activity logs, session recordings, and the cookies installed or utilized on the Payee User’s device; and
• Direct interactions and communications with us: including recordings and transcripts of your calls and correspondence with us, e.g., for user enablement, support and training purposes.

Third Party Data: 

• Account login information: e-mail address and, when applicable, hashed password or other information used for authentication and access control;
• Profile and contact information: full name, title, company name, e-mail and phone number, profile picture, role, and additional information submitted by Customer’s Users or their organization;
• Platform usage information: technical usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, geolocation and language settings used), connectivity data, activity logs, session recordings, and the cookies installed or utilized on the Third Party’s device; and

*PAYMENT BOOK processes Personal Data  (1) as a processor on our Customer’s behalf, in accordance with their reasonable instructions in connection with the Services; and (2)  as a controller for our own legitimate purposes, as further explained in Section 2 and Section 10 below.

For Europe Residents: The personal information that we may collect, or may have collected from consumers in the preceding twelve months, fall into the following categories established by the Europe Consumer Privacy Act and Europe Privacy Rights Act (collectively, “Europe Privacy Laws”), as applicable, depending on how you engage with PAYMENT BOOK:

• Identifiers, such as your name, alias, address, phone numbers, or IP address;
• personal information as described in subdivision (e) of Section 1798.80 of the Europe Civil Code, such as a credit card number;
• characteristics of protected classifications under Europe federal law, such as age or gender, for example if we conduct due diligence and other identification checks;
• commercial information, such as purchase activity;
• Internet or other electronic network activity information, including browsing history, search history, and information regarding your interaction with the Services;
• geolocation data, such as the location of your device or computer;
• audio, visual, electronic or other similar information, including when you communicate with us by phone or otherwise;
• professional or employment-related information, for example data you may provide about your business;
• inference data, such as information about your preferences; and
• education information, such as information about enrollment status, fields of study, or degrees, honors, and awards received.

Sensitive Personal Information: The Sensitive Personal Information (as defined under Europe Privacy Laws) that we may collect, or may have collected from consumers in the preceding twelve months is as follows:

• Copies of identification documentation, such as passports or driver’s licenses; and
• Financial Account information, such as account number, transit and routing numbers and contact information related to banking details.

Legal Basis for Collection: GDPR

For Personal Data that is subject to the EU General Data Protection Regulation (“GDPR”), the lawful basis for collecting and using your Personal Data is consent, where you have provided your consent, or for fulfilling our contractual obligations in providing our Services. For instances where your consent is not obtained or there is no contractual obligation, we collect and use your Personal Data in our legitimate interests (which are not overridden by your data protection interests), such as operating our business, understanding and improving our products, hosting events, communicating with you about our products, services, events or related resources, improving our Sites, and protecting our legal rights and interests.  

You are not legally required to provide us with any personal data and may do so (or avoid doing so) at your own free will. If you provided your consent for us to collect and use your Personal Data, you may withdraw that consent at any time. If you do not wish to provide us with your personal data, or to have it processed by us or any of our service providers (per Section 5 below), please contact the applicable Customer or Supplier (if you are a Customer User or Supplier Staff) and contact us (if you are a Prospect or Payee) about your personal data request (per Section 11 below). By accessing and/or using any of the Services, you signify and affirm your informed consent to the collection and processing of your Personal Data as defined and explained in this Privacy Policy. 

2. DATA USES

PAYMENT BOOK processes the Personal Data described in Section 1 as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services. PAYMENT BOOK also uses artificial intelligence and similar technologies for processing Personal Data within the Services.

Specifically, we use Personal Data and technical usage data, for the following purposes:

1. To facilitate, operate, and provide our Services, including determining your initial and continued eligibility to use our Services;
2. To authenticate the identity of our Customer Users, Third Parties and Payee Users, which may include verifying Personal Data against third party data, such as data belonging to credit reference agencies or other public sources;
3. To facilitate and manage access to and use of our Services, including account creation, login and deletion;
4. To provide you with customer care, assistance and technical support services;
5. To further develop, customize and improve the Services, and to improve your user experience;
6. To facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively; 
7. To contact you with general or personalized service-related messages, or with promotional messages, in accordance with Section 7 below, and to facilitate, sponsor and offer certain events and promotions;
8. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
9. To create aggregated statistical and research data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we or our business partners and customers may use to provide and improve our respective services, or for any other purpose; 
10. To enforce and apply our agreements, including for billing and collection purposes; and
11. To comply with our legal, regulatory, compliance and contractual obligations, including in particular as a business and a financial services provider.

For Europe Residents: The personal information that we may have used and/or disclosed about consumers in the preceding twelve months fall into the following business purposes, as established by the Europe Privacy Laws:

• To facilitate, operate, and provide our Services;
• To verify the identity of our Users;
• To determine your eligibility to use our Services;
• To further develop, customize and improve our Services, and to provide you with any such enhanced Services;
• To provide customer assistance and technical support;
• To contact our Users, Consumers, customers, and website visitors with general and personalized service-related notices, surveys and promotional messages including marketing and advertising messages;
• To create aggregated statistical data and other aggregated and/or inferred Non-Personal Information, which we, our Users or our business partners may use to operate and improve our respective services, or for any other purpose;
• To manage and assess risk, enhance our data security and fraud prevention capabilities, and help protect against error, fraud or any illegal or prohibited activity;
• To act as permitted by, and to comply with any legal or regulatory requirements;
• To conduct any additional activities that may require the use of your Personal Information (as that term is defined under Europe Privacy Laws), for which we will request your consent in advance; and
• Any other usage delineated in PAYMENT BOOK’s Privacy Policy.

Sensitive Personal Information: PAYMENT BOOK uses, and has used and/or disclosed Sensitive Personal Information (as defined under Europe Privacy Laws) about consumers in the preceding twelve months that fall into the following business purposes:

• To facilitate, operate, and provide our Services, such as facilitating payments;
• To verify the identity of our Users, and to assist in preventing fraud and other financial crimes; and
• To determine your eligibility to use our Services.

5. DATA SHARING

PAYMENT BOOK shares Personal Data as provided below. 

Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your Personal Data in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. All such disclosure requests will be reviewed by PAYMENT BOOK to determine to what extent, if any, PAYMENT BOOK is required to comply with such request. PAYMENT BOOK will consult with its legal advisors on the request to determine if we are permitted to notify you about such requests. Such disclosure or access may occur if we believe in good faith that: (1) we are legally compelled to do so; (2) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements fraud, or other wrongdoing; or (3) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services. Unless PAYMENT BOOK is prohibited from doing so by applicable laws or the applicable legal request, PAYMENT BOOK may notify you before disclosing Personal Data, so you may take the necessary steps to object or seek protection from disclosure. 

Service Providers: We engage selected partners, and third-party contractors to perform services complementary to our own, and to support the operation of our business. Such Service Providers or contractors include hosting and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platforms, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, capital providers, and correspondents, banks, financial institutions, credit bureaus, collection agencies, customer engagement services, billing and payment processing services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems, service providers that help us verify your identity and help us comply with our legal and regulatory obligations to screen and monitor transactions; recruiters and companies that provide background checking services; and our business, legal, tax, financial and compliance advisors (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating, supporting, and enhancing our Services, and may only use it for such purposes. 

Third-Party Websites and Services: Our Services may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third-party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites and third-party services. To the extent that our Service Providers contact you in order to offer or promote our Service, they may additionally interest you in their own services. Should you decide to engage in such activities with PAYMENT BOOK’s Service Providers, please note that such engagement is beyond the scope of PAYMENT BOOK’s Terms of Service and Privacy Policy and will therefore be covered by our Service Provider’s terms and privacy policy.

Sharing Data with Other Users: Payee Data and Third Party Data is typically shared with and is available to Customer Users within the relevant Customer account. Customer Data is shared with the administrator or other users of their Customer account. In such cases, sharing such data means that the administrator or other users of the account may access it on behalf of the Customer, and will be able to monitor, process and analyze the Personal Data contained therein. This includes instances where you may contact us for help in resolving an issue specific to you or to a team of which you are a member (and which is managed by the same Customer). Please note that PAYMENT BOOK is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer, where the Customer acts as the Data Controller of such data (as further described in Section 10 below). Supplier Data is typically shared with other users of the Services, primarily through access to the Supplier’s site in relation to the Services.

Events: PAYMENT BOOK may receive from, and share with a third-party event host, Personal Data collected at events either managed by PAYMENT BOOK or by a third party. For any event hosted by a third party, the collection and use of all Personal Data will be governed by the applicable third party’s privacy policy, and the terms provided to individuals at the applicable event.

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of PAYMENT BOOK, any of our Customers, their users, Payees, our Prospects, or any members of the general public.

PAYMENT BOOK Subsidiaries and Affiliated Companies; Change of Control: We may share your Personal Data internally within our affiliates for the purposes described in this Privacy Policy. In addition, should PAYMENT BOOK or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant, personal data may be shared with the parties involved in such an event. If we believe that such an event might materially affect your Personal Data then-stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

Additional Sharing: PAYMENT BOOK may share your Personal Data in additional manners, pursuant to your explicit consent, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous.

For Europe Consumers: PAYMENT BOOK does not sell Personal Information for monetary or other value. In the preceding twelve months, we have not sold any Personal Information of consumers, as those terms are defined under the Europe Privacy Laws. PAYMENT BOOK has shared Personal Information as noted above within the preceding 12 months.

6. COOKIES AND TRACKING TECHNOLOGIES

PAYMENT BOOK and our Service Providers use cookies and other technologies on our Sites and within our Services, for performance, tracking, analytics, personalization purposes and in order to provide you with a better experience. We may share non-identifiable/aggregated extracts of such information with our partners for our legitimate business purposes.

Cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session – these are the “Session Cookies”, others last for longer periods and are called “Persistent Cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools (for example, we use Persistent Cookies to remember your login details and make it easier for you to login the next time you access the Platform). 

The following describes different categories of cookies and how we might use them on our Sites and within our Services. 

Required Cookies: These cookies are necessary for the functionality of our Sites, and include session cookies needed to transmit authentication and security cookies. These cookies cannot be opted out of, as they are required for website functionality. 

Functional Cookies: These cookies assist us with enhancing the function and performance of our Sites, including capturing analytics of website traffic, assisting with market research, and providing non-targeted advertising. 

Google Analytics: We use Google Analytics to collect information to maintain and improve the use of our Sites and Services. Google Analytics collects information such as how often users visit the Services, which pages they visit when they do so, and which other sites they used prior to coming to our Services. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics. Further information about your option to opt-out of these analytics services is available here. 

Advertising Cookies: These cookies track a user’s activity across websites in order to understand a user’s interests, and to direct marketing to the user. More information on how we use advertising cookies in relation to interest-based advertising is outlined below. 

Interest-Based Advertising: Interest-based ads are sometimes referred to as personalized or targeted ads. We and our marketing partners may show interest-based ads to display features, products, and services that might be of interest to you. In providing interest-based ads, we follow the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance (a coalition of marketing, online advertising, and consumer advocacy organizations). Some of these companies deliver advertising and content based on your activity across websites, devices, and over time. These companies may process your information for their own purposes of operating their advertising networks in accordance with their own privacy policies. 

• Alphabet
• Microsoft Corporation
• LinkedIn Corporation
• X(Ex.: Twitter)
• Facebook (on and off their service)

9. DATA SUBJECT RIGHTS

Individuals have the following rights concerning their personal data under global privacy laws, including but not limited to, Europe Privacy Laws and GDPR. 

• The right to access personal data held about you.
• The right to request that we rectify any personal data we hold that is inaccurate or misleading.
• The right to request the erasure/deletion of your personal data (e.g., from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims, or in accordance with legal requirements.
• The right to object, to or to request restriction, of certain processing activities.
• For Europe consumers, the right to opt out of, and limit the sale of and sharing of your personal data, and to limit the use and disclosure of Sensitive Personal Information.
• The right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller.
• The right to object to profiling.
• The right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.
• For individuals subject to GDPR, the right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality.
• The right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

If you wish to exercise your privacy rights under any applicable law, including Europe Privacy Laws and GDPR, in relation to Personal Data held with PAYMENT BOOK, please login to your account via the Services or the relevant website (where you originally uploaded this personal data) and view, edit or deactivate the data saved in that account. If you do not have such an account, or if you wish to exercise your right to restrict or object to such processing, to port such personal data (if applicable), or to exercise any similar rights afforded to data subjects under the laws that apply to you – please contact us by e-mail at: info@payment-book.com. If you provided personal information to a PAYMENT BOOK Customer and believe it is being processed by PAYMENT BOOK on behalf of that Customer, please make any requests or queries regarding personal data to that Customer directly. 

Please note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact any personal data related to others from the data which we will make available to you.

Please also note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions. 

We will respond within thirty (30) days upon receipt of your personal data request; or (b) if additional time is required to meet your request, we will notify you by mail or electronically of the reason and extension period, provided, however, such extension shall not exceed forty-five (45) days.

We do not charge a fee to process or respond to your personal data request, provided that it is not excessive, repetitive, or manifestly unfounded.

For Europe consumers: For specific inquiries concerning Europe Privacy Laws, you must submit a Verifiable Consumer Request to PAYMENT BOOK via email to info@payment-book.com and include all of the following information:

• Your relationship with PAYMENT BOOK (payer, payee, or advertising recipient);
• The email address through which PAYMENT BOOK communicates with you;
• The name you have registered with PAYMENT BOOK or to whom PAYMENT BOOK addresses you;
• A contact phone number so PAYMENT BOOK may call you in order to verify your identity; and
• Which rights you are exercising:
  • Your Right to Access your Data,
  • Your Right to limit use of your Sensitive Information, and/or
  • Your Right to Delete your Data.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a Verifiable Consumer Request does not require you to create an account with us. We will only use Personal Information provided in a Verifiable Consumer Request to verify the requestor’s identity or authority to make the request.

Please note that any disclosures we provide will only cover the 12-month period preceding the Verifiable Consumer Request.