A. This Policy
This Policy explains how we Process Personal Data. This Policy may be amended or updated from time to time, so please check it regularly for updates. This Policy is issued by Innout Payments which is made up of each of the Controller entities ("Innout Payments", "we", "us" and "our") and is addressed to individuals outside our organisation with whom we interact in our course of business as a Merchant of Record, including customers, visitors to our Sites, other users of our products or services, personnel of corporate customers and vendors, applicants for employment, and visitors to our premises (together, "you").
Please note that not all provisions of this Policy will apply to you and your Personal Data, as this will depend on your specific relationship with Innout Payments.
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.
B. Collection of Personal Data
Summary: We collect or obtain Personal Data: when that data is provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you appoint us as your Merchant of Record or if you make a purchase from Innout Payments); when you make Personal Data public (e.g., if you make a public post about us on social media); when you visit our Sites; when you register to use any of our Sites, products, or services; or when you interact with any third party content or advertising on a Site; we may also receive Personal Data about you from third parties (e.g., law enforcement authorities).
We collect or obtain Personal Data about you from the following sources:
- Data provided to us: We obtain Personal Data when such data is provided to us (e.g., where you contact us via email or via our Sites, or by any other means, or when you provide us with your business card, or when you submit a job application).
- Data we obtain in person: We obtain Personal Data during meetings, at trade shows, during visits from sales or marketing representatives, in person interviews or at events we attend.
- Collaborations: We obtain Personal Data when you collaborate with us in research or in an advisory/consultancy capacity.
- Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g. we provide a service to you, or to your employer).
- Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media.
- Site data: We may collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
- Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, products, or services.
- Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).
C. Creation of Personal Data
We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, products, or services, including where that data is collected from different sources.
D. Categories of Personal Data we Process
We Process the following categories of Personal Data about you:
- Personal details: given name(s); preferred name.
- Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
- Contact details: correspondence address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
- Consent records: records of any consents you have given, together with the date and time; means of consent and any related information.
- Purchase details: records of purchases and prices; and consignee name, address, contact telephone number and email address.
- Payment details: invoice records; payment records; billing address; payment method; cardholder or account holder name; card payment identifiers; payment amount; and payment date.
- Data relating to your use of our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; and usage data.
- Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
- Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
E. Sensitive Personal Data
We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business as a Merchant of Record. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.
Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
- Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law.
- Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime.
- Establishment, exercise or defence of legal claims: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims.
- Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing.
F. Purposes of Processing and Legal Bases for Processing
The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:
- Provision of Sites, products, and services: providing our Sites, products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, products, or services.
- Compliance checks: fulfilling our regulatory compliance obligations; 'Know Your Client' checks; and confirming and verifying your identity.
- Operating our business: operating and managing our Sites, our products, and our services; providing content to you; displaying advertising and other information to you.
- Communications and marketing: communicating with you via any means to provide news items and other information in which you may be interested.
- Management of IT systems: management and operation of our communications, IT and security systems; and audits of such systems.
- Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises.
- Financial management: sales; finance; corporate audit; and vendor management.
- Surveys: engaging with you for the purposes of obtaining your views on our Sites, our products, or our services.
- Security: physical security of our premises; CCTV recordings; and electronic security.
- Investigations: detecting, investigating and preventing breaches of policy, and criminal offences.
- Legal compliance: compliance with our legal and regulatory obligations under applicable law.
- Fraud prevention: Detecting, preventing and investigating fraud.
G. Disclosure of Personal Data to Third Parties
We disclose Personal Data to other entities within the Innout Payments group, for legitimate business purposes and the operation of our Sites, products, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:
- You and, where appropriate, your appointed representatives
- Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation
- Accountants, auditors, consultants, lawyers and other outside professional advisors to Innout Payments
- Third party Processors (such as payment services providers etc.)
- Any relevant party, regulatory body, governmental authority, law enforcement agency or court
- Suppliers to the extent necessary to provide a product requested by you
H. International Transfer of Personal Data
Because of the international nature of our business, we transfer Personal Data within the Innout Payments group, and to third parties as noted above, in connection with the purposes set out in this Policy. For this reason, we may transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
I. Data Security
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk.
J. Data Accuracy
We take reasonable steps to ensure that:
- Your Personal Data that we Process is accurate and, where necessary, kept up-to-date
- Any of your Personal Data that we Process that is inaccurate (having regard to the purposes for which it was Processed) is erased or rectified without delay
K. Data Minimisation
We take reasonable steps to ensure that your Personal Data that we Process is limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.
L. Data Retention
We take reasonable steps to ensure that your Personal Data is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data includes maintaining an ongoing relationship with you, legal obligations, and applicable limitation periods.
M. Your Legal Rights
Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:
- The right not to provide your Personal Data to us
- The right to request access to, or copies of, your Relevant Personal Data
- The right to request rectification (or correction) of any inaccuracies in your Relevant Personal Data
- The right to request, on legitimate grounds: erasure of your Relevant Personal Data or restriction of Processing
- The right to have certain Relevant Personal Data transferred to another Controller
- The right to withdraw consent
- The right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority
N. Cookies and Similar Technologies
When you visit a Site we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits.
O. Direct Marketing
We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, products, or services that may be of interest to you. You may unsubscribe for free at any time.
You may change your preferences, or unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication and updating your communication preferences.
P. California Consumer Privacy Act Disclosures
Under the California Consumer Privacy Act as amended ("CCPA"), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents ("Consumers"). Consumers are also afforded additional rights with regard to the Personal Information that we collect about them that include the rights of access, deletion, and to be free from discrimination.
We do not Sell any Personal Information to third parties. In particular, we do not Sell the personal information of minors under 16 years of age.
Q. Contact Information
For questions about this Privacy Policy, please contact us at:
Email: main@innoutpayments.com