PRIVACY NOTICE

BACKGROUND:

All companies within the Nuvei Group (hereafter ‘Nuvei’) understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone that uses our services, and that we must identify to comply with our legal and contractual obligations. We only collect and use your personal data as described in this Privacy Policy. Any personal data we collect will only be used as permitted by law.

Please read this Privacy Notice carefully and ensure that you understand it.

1. Information About Us

This on-boarding process operated by various companies within the Nuvei Group. The company that controls the use of this data is the company that you are engaging with or that the company you own, control or manage is engaging with. Information on the relevant companies can be found here.

Data Protection Officer: James Lillis

Email Address: [email protected].

Postal address: One Smart’s Place, 5th Floor, London WC2B 5LW, United Kingdom

2. What Does This Policy Cover?

This Privacy Notice applies only to your use of Trulioo and related processing for the purposes of on-boarding.

3. What Is Personal Data?

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:

10. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10.
11. The right to access the personal data we hold about you. Part 9 will tell you how to do this.
12. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 10 to find out more.
13. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We hold. We are obliged to retain certain information related to due diligence for prescribed periods of time.
14. The right to restrict (i.e. prevent) the further processing of your personal data.
15. The right to object to us using your personal data for a particular purpose or purposes.
16. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
17. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
18. Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the relevant data protection authority. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 10.

5. What Personal Data Do You Collect and How?

Depending on the identification document provided, we collect the following information:

Name

Date of Birth

Gender

Date of Identification Document Issue

Issuer of Identification Document

Date of Expiry

MRZ1

City

MRZ2

Postal Code

MRZ3

National ID Number

Passport Number

Last Name

Nationality

Address

Place of Birth

Document Country Code

State Province

Images of your identification document

Images of you

If you send us an email, we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, we are the data controller responsible for such personal data.

We process your personal data when it is necessary for the purposes of our legitimate interests in preventing fraud. We process your personal data in compliance with legal obligations on the prevention of money-laundering to which we are subject. We may rely on your consent to the use of Trulioo to support a faster on-boarding process.

6. How Do You Use My Personal Data?

Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Part 7, below.

Any and all emails containing your personal data will be deleted no later than five years after the end of your business’s contract with us, and no other personal data will be retained for any longer than is necessary.

We will not share any of your personal data with any third parties for any purposes other than storage on an email and/or web hosting server, or for verifying the information you provided to us.

7. How and Where Do You Store My Data?

We will store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law.

We store some or all of your personal data in countries outside of the EEA. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the Data Protection Legislation as follows:

We ensure that your personal data is protected under binding corporate rules.

We will store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data.

We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation.

Please contact us using the details below in Part 10 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.

Personal data security is essential to us, and to protect personal data, we take the following measures:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

8. Do You Share My Personal Data?

We share your personal data with Trulioo, subject to your consent, to facilitate an electronic on-boarding process. Trulioo will delete this data within three days, and Nuvei will retain the only copy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is transferred to a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 7.

9. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

10. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: [email protected].

Postal Address: One Smart’s Place, 5th Floor, London WC2B 5LW, United Kingdom

11. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change our business in a way that affects personal data protection.

Any changes will be immediately posted here Site and you will be deemed to have accepted the terms of the Privacy Notice on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Notice was last updated on the 12th of July, 2022.