CENTIMENT LIMITED a company incorporated under the laws of the United Kingdom, with registration number 11823663 and register address in 130 Old Street, London, England, EC1V 9BD (“we” or “us”) are committed to protecting your information and respecting your privacy.
If we are going to use your personal data in a manner that is different from the uses set out below, we will notify you by email. You may object to any new use or change in use of your personal data by contacting us as set out in section 11 below. We will treat such objection as a notice to terminate the Merchant Account.
INFORMATION WE COLLECT
Information We Collect From You
We may collect and process the following data about you (for the purpose of this section 2 (“Information We Collect”) ‘you’ shall include any person visiting our website, a company applying for credit card acquiring services, its directors and its beneficial owners):
Your full name, address, email address, telephone number, date of birth and bank or payment card details and any proof of your identity and/or address that we may require; Details of any bank account (including but not limited to, account holder, account name, account number, sort code, routing number);
Correspondence that you send us;
Calls that we make to you or you make to us;
Surveys that you complete;
Information collected through cookies;
Your IP address, log-in times, operating system ad browser type;
Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access whilst visiting our Website.
Information We Collect from Third Parties about You
In order to fulfill our legal obligations to prevent fraud and money laundering, we will obtain information about you from third party agencies, including your financial history, court judgments and bankruptcies, from credit reference and fraud prevention agencies when you open an Account and at any time when we feel it is necessary to prevent fraud and minimize our financial risks.
AUTHORISATION TO USE YOUR INFORMATION
You authorize us to use information collected and held in the following ways:
to be able to process a merchant application and provide its services;
to operate and administer the Merchant Account and to provide services that you have requested;
to carry out instructions to make and receive payments and undertake transactions using our services;
to allow you to participate in interactive features of the Website;
to notify you about changes to our service(s);
to improve our internal customer training;
to comply with financial services regulations including retention of financial information and transactions, which shall include — but not be limited to – the detection and prevention of fraud and other criminal activity which we are bound to report; to conform with any laws, rules, or regulations imposed on us by any relevant authority, regulator or card schemes;
for due diligence procedures, which shall include financial and identity checks, fraud prevention checks, anti-money laundering, and credit checks;
for customer service, including answering questions and responding to feedback and complaints;
to enhance the security of our services;
for direct marketing purposes and to provide you with information, products or services that are requested from us or which we feel may be of interest.
You consent to the processing of such data for the purpose specified in this section and consent to the disclosure of information given above to, and to the exchange thereof with other employees of the Company, your Provider if any, their subsidiaries, agents, partners, competent authorities, credit institutions, card schemes or other carefully selected organizations and companies. You understand that you have a right of access to, and the right to rectify, your personal data.
SECURITY AND RETENTION
We are committed to ensuring that your information is secure. To prevent unauthorized access or disclosure of information we have physical, electronic and managerial procedures in place to keep your information safe.
However, this high level of protection can only be effective if you follow certain security practices yourself. You must never share your Merchant Account or login details with anyone. If you are concerned that any of your login details have been compromised, you can change them any time once you are logged on but you should always also immediately contact Customer Services and tell us why you think your login details have been compromised. Details of how to contact Customer Services are available from the “Contact” section of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We are by law required to retain certain records for a period of at least five years after closure of your Merchant Account which will include your personal data such as your name, contact details, customer number and transaction history etc. Otherwise, we will delete and destroy all personal data that we hold about you when you (or we) terminate your Merchant Account.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our ultimate holding company and its subsidiaries who are based in different countries. This may be necessary in order to, among other things, fulfill your request, process your payment details and transactions, provide support services and monitor fraudulent activities.
Fraud and Credit Reference Agencies
When you open a Merchant Account, at intervals of up to every six (6) months and at any other time we feel it is necessary to do so to protect our financial interests and prevent money-laundering or fraud, we share certain information about you and your Merchant Account, financial history and transactions as part of our normal business operations with our identity verification service providers and credit reference agencies to identify and verify users, to limit our exposure to fraud and other criminal activities and to manage our financial risk.
We may also disclose your personal information to:
a prospective buyer of our business or a buyer of a substantial number of the shares in our business; the police, other lawful enforcement body, regulatory body or court if we are under a duty to disclose or share your personal data , or to protect the rights, property, or safety of ourselves or our group companies, our customers, or others;
third parties who referred you to us initially and to whom we owe a commission payment as a result of the referral. Where the commission payment is based on transaction volumes, numbers or types of transactions, we may share that information with that third party.
COMMUNICATING WITH YOU
We may contact you by email to the primary email address registered with your Merchant Account or by telephone to the contact telephone numbers you have provided when registering for your Merchant Account. You can change your primary email address and/or contact telephone number at any time, subject to the provisions of section 8 below.
You may also receive system-generated transactional emails such as confirmation of uploads, notification of receipt of payments, notification of password changes etc. which are necessary for the proper operation and administration of your account.
Newsletters and Marketing
As a Merchant Account holder, you will occasionally receive information by email from us, unless you have chosen not to receive such communication, and if you have consented to do so from our group companies too, about products, services and special deals which we think will be of interest to you via our newsletter. You can change whether or not you receive newsletters from us and our group companies in any newsletter email by clicking on the appropriate ‘opt-out’ link. Please note that you will still receive communication regarding your Merchant Account.
From time to time we do share aggregated information about our customers’ use of our website and services with other companies for research and analysis purposes, but you cannot be identified from this aggregated information.
Phishing is the name given to attempts to steal personal details and financial account details from a website user. “Phishers” use fake or “spoof” emails to lead users to counterfeit websites where the user is tricked into entering their personal details, such as credit card numbers, user names and passwords. WE WILL NEVER SEND EMAILS ASKING YOU FOR SUCH DETAILS AND OUR STAFF WILL NEVER ASK YOU FOR YOUR PASSWORD.
If you do receive such an email or are asked for your password by anyone claiming to work for us please forward the email or report the incident by email to our Customer Services.
LINKS TO OTHER WEBSITES
Our Website may, from time to time, contain links to and from the websites of our partner networks. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
ACCESSING AND UPDATING YOUR INFORMATION
If your personal details (such as your name, address, or telephone number) change you must update your details by contacting Customer Services via the “Contact” section of the Website as soon as you can. You also have the right to request the blocking or erasure of data which has been processed unlawfully. We shall not be liable for any loss arising out of your failure to keep your personal details up to date. You have the right to access information that we hold about you. To do so, please contact us at the address given at the end of this policy. Access may be subject to an administrative fee of up to EUR10. In the event that you (or we) terminate your Merchant Account, in accordance with the General Data Protection Regulation, you also have the right to request that we delete your personal details from our systems without undue delay. We will endeavor to complete this request insofar as applicable laws and regulations to prevent money-laundering or fraud and other financial services laws allow us to do so.
A cookie is a small amount of data which contains information that is downloaded to the device from which you access our site. Cookies are useful because they allow us and other websites to recognize your device.
Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. For example, they can allow you to navigate between web pages of our site and remember your preferences such as your language selection.
Types of Cookies and Consent
In summary, we use the following types of cookies:
Strictly necessary cookies — These are cookies which are essential for our site to operate such as those which identify you so you can log into your Merchant Account. They allow you to move around our website and use the services you have requested. These cookies will be activated when you enter our site and as you use our site.
Compliance cookies — These include cookies which are necessary to assist in meeting our regulatory compliance obligations, such as anti-money laundering and anti-fraud obligations, and prevent your Merchant Account from being hijacked. These cookies will be activated when you enter our site and as you use our site.
Performance cookies — These are cookies that help us to improve how our site works and to deliver a better service to you. For example, they will assess which pages you visit most often or if you get an error message. All information collected by these cookies is aggregated and therefore anonymous.
Functionality cookies — These cookies allow us to deliver a more personalized service to you and allow our site to remember choices you have made such as the language you prefer or the region you are in. Third Party cookies — When you visit a page on our site with content embedded from third parties, for example, YouTube or Twitter, cookies may be downloaded onto your device. We do not set or control these cookies. If you are concerned about the types of cookies that may be downloaded you check the third party websites for more information about these cookies.
We may use other cookies from time to time in accordance with this policy. By using our sites and other online services, you acknowledge that we may use some or all of the cookies as set out above and you agree that we can place Performance and Functionality Cookies on your device when you use our site. If you do not agree to this you should cease using our sites and online services or adjust your browser settings. Please see section 9.3 below.
Should you fail to resolve any issues regarding our processing of your personal details with our Customer Support staff, you have the right to lodge a complaint with the supervisory authority of your home Member State if you feel that your personal details have not been processed in a legal manner in line with the General Data Protection Regulation.