Effective October 2019
LumiPay and its partners offer services that enable platforms and business merchants to run their business and safely conduct online payment transactions.
This policy also describes how we use Personal Data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third-parties carefully.
LumiPay may obtain Personal Data about you from various sources to provide our Services and to manage our Sites. If you are a member of the public, Lumi Pay will generally not collect your Personal Data directly from you. Your agreement with the relevant LumiPay Business Merchant should explain how they share your Personal Data with LumiPay, and if you have questions about this sharing, then you should direct those questions to the LumiPay Business Merchant.
2. Personal Data We Collect
Personal Data that we collect about you
Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites will be apparent from the context in which you provide the data. In particular:
1. When you complete our online form for LumiPay Services we collect your full name, email address, telephone number, who your current Services provider is, the industry your business operates in, how you intend to take card payments, and the amount you will be processing.
2. When you respond to LumiPay emails we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call LumiPay. If you contact us by phone as a LumiPay Business Merchant, we may collect additional information in order to verify your identity.
3. If you are a LumiPay Business Merchant, you will provide your contact details, such as name, postal address, telephone number, and email address. As part of your business relationship with us, we may also receive financial and personal information about you, such as your date of birth and government identifiers associated with you and your organization (such as your social security number, tax number, or Employer Identification Number).
If you are a Customer, when you make payments or conduct transactions through a LumiPay Business Merchants website or application, we may receive your transaction information. Depending on how the LumiPay Business Merchant implements our Services, we may receive this information directly from you, or from the LumiPay Business Merchant. The information that we collect will include payment method information (like credit card or debit card information, purchase amount, date of purchase, and payment method). Different payment methods might require the collection of different categories of information. The LumiPay Business Merchant will determine the payment methods that it enables you to use, and the payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you by the LumiPay Business Merchant.
When we conduct fraud monitoring, prevention and detection activities, we may also receive Personal Data about you from our business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may use technology that helps us assess the risk associated with an attempted transaction that is enabled on the LumiPay Business Merchant’s website or the application that collects information.
You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program, or promotions, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.
b. Information that we collect automatically on our Sites.
Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
We may collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We use Google Analytics on our Sites to help analyze your use of our Sites and to run diagnostics of technical issues.
3. How We Use Personal Data
a. Our products and services.
We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our Business Merchants, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete payment transactions and to provide payment-related services to our Users.
b. Marketing and events-related communications.
We may send you email marketing communications about LumiPay products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. When we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.
c. Interest-based advertising.
When you visit our Sites or online services, we collect information about your online activities over time to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). Where required by applicable law, we will obtain your consent prior to processing of your information for the purpose of interest-based advertising.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests and browsing context (for example, the time and date of your visit to our Sites, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.
4. How We Disclose Personal Data.
LumiPay does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.
a. LumiPay – We share Personal Data with other LumiPay entities in order to provide our Services and for internal administration purposes.
b. Service providers – We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorise such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.
c. Business partners – We share Personal Data with third party business partners when this is necessary to provide our Services to our Business Merchants. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment method providers (such as credit card networks) when we provide payment processing services.
e. Corporate transactions – In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganisation, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.
f. Compliance and harm prevention – We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of LumiPay, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
5. Your Rights and Choices.
You have choices regarding our use and disclosure of your Personal Data:
a. Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.
b. How you can see or change your account Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to your LumiPay account or by contacting us.
c. Your data protection rights. Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:
• The right to request confirmation of whether LumiPay processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
• The right to request that LumiPay rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
• The right to request that LumiPay erase your Personal Data in certain circumstances provided by law;
• The right to request that LumiPay restrict the use of your Personal Data in certain circumstances, such as while LumiPay considers another request that you have submitted (including a request that LumiPay make an update to your Personal Data); and
• The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.
Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.
d. Process for exercising data protection rights. In order to exercise your data protection rights, you may contact LumiPay as described in the Contact Us section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.
For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
If you are a Customer of a LumiPay Business Merchant, please direct your requests directly to them. For example, if you are making, or have made, a purchase from a business using LumiPay Services, and you have a request that is related to the payment information that you provided as part of the purchase transaction, then you should address your request directly to the merchant.
6. Retention and Security
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organisational, technical and administrative measures designed to protect Personal Data within our organisation against unauthorised access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.
If you are a LumiPay Business Merchant, we retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services to you, even if you close your LumiPay account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
7. International Data Transfers.
Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.
9. Links To Other Websites.
The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.
10. Contact Us
LUMI TRADE LTD
71-75 SHELTON STREET, COVENT GARDEN