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  1. About this Privacy Notice

    Prudent Pig takes the protection of your privacy and personal data very seriously! We want you to understand how we protect your privacy when we obtain personal data from you, how we use your personal data, what your rights are in this respect and how we safeguard it while you use and interact with our services, visit our websites and use its functionalities. For this reason, we are providing you with this Privacy Notice which we kindly ask you to read before you engage with us.

    By using our services, you acknowledge that you have read this Privacy Notice and understood that any personal data you provide to us is supplied at your own free will and shall be used in accordance with the purposes described in this Notice. If you do not understand this Privacy Notice, we recommend you do not use our services.

    We reserve the right to change and/or update our Privacy Notice at our discretion and at any time. Where required, you will be notified accordingly and in advance about these changes and or updates, which we kindly ask you to read carefully and make sure you understand. Nevertheless, we advise you to check our Privacy Notice from time to time to ascertain whether any changes took place.

  2. About Us

    Prudent Pig Ltd (“Prudent Pig”, “we”, “us”, or “our”) is a private limited company established under the laws of England and Wales, registered with the Companies House under number 13030110, with registered address located at 1st Floor, 239 Kensington High Street, London, W8 6SN, authorised by the Financial Conduct Authority as a payment institution (reference number: 945943) to provide certain payment services.

  3. Applicability

    This Privacy Notice applies to the following individuals with which we envisage to interact in the course of our business:

    • Merchants, their legal representatives, ultimate beneficial owners and authorised representatives;

    • End-users/customers/payees of merchants involved in any transaction with our payment institution; and

    • Visitors of our website.

  4. Personal data collected and purpose of processing

    As used in this Privacy Notice, ‘personal data’ means any information that can be used to individually identify you, directly or indirectly, alone or along with other information. The categories and volume of personal data that we collect vary depending on: i) the identified relationship we have with you; and ii) our purposes for processing your personal data.

    The collection of personal data is done in the following manner, but not limited to:

    • directly from you through:

      • manual input and/or intervention from you where we ask you for information that includes your personal data; and/or
      • automatically generated through your interaction with our services and/or website;
    • indirectly through:

      • publicly available sources; and/or
      • third parties;

    Depending on your relationship with us, we collect the following categories of personal data: Cookie Policy

    1. Merchants` legal representatives, ultimate beneficial owners and authorised representatives

      The personal data we collect and process about legal representatives, ultimate beneficial owners and authorised representatives of merchants may include but is not limited to: name, address and contact details (e-mail address and phone number); financial and credit card information; nationality and country of residence; government-issued identification documents; documents confirming the right of representation; other personal data that you may need to provide us to:

      • Conduct our due diligence on your business and conclude a service agreement with you.

      • Carry out our obligations relating to your contract and notify you of any changes or updates to our services, terms of service, scheduled maintenance, billing issues.

      • Comply with our legal obligations on anti-money laundering and counter-terrorist financing legislation. In such situations, we may use and process personal data about you from publicly available sources, credit reference or fraud prevention agencies or check data against government sanction lists, either directly, or using identity verification providers or due diligence and screening information providers, as necessary to confirm your identity and prevent fraudulent activities and money laundering.

      • Comply with any reporting obligations or investigations from government authorities or financial institutions.

      • Analyse and understand how our services are used based on your interaction with them for improvement and further development.

      • Administer our services for internal operations, including security and business continuity, troubleshooting, data analysis, testing, research, statistical and survey purposes.

      • Provide you with personalised offerings of our products and services through emails or text messages if you have subscribed to such communications. You may unsubscribe from such personalized offers. You have the right to withdraw your consent or to object to personalized direct marketing or commercial activities, including profiling related to these activities.

      As a general rule, we avoid processing special category personal data. However, where it is required by law, we may process special categories of personal data such as information about race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sexual orientation. When this is the case, we shall only process this information in strict accordance with the law governing this type of information and apply strict security measures.

    2. Merchants` end-users / customers / payees involved in any transaction with our payment institution

      The personal data we collect and process for this categories of individuals include: full name; billing address; delivery address; email address; information about the products or services purchased; information about the card used, such as the type of card, last 4 digits of your account number, card expiration date, name of card; information about the transaction such as date, time, amount, currencies used, exchange rate; messages sent or received with the payment; information about device and location, such as IP address and any other data needed to:

      • Facilitate the payment between you and the merchant.

      • Authenticate and validate payments to mitigate and protect against fraudulent activities, for example if you are the victim of identity theft, if your personal data was disclosed or hacked.

      • Facilitate payments dispute or chargeback with a financial institution, if you exert your right of refusal on purchases made or if your transaction is subject to such situations.

      • Analyse and understand how our services are used based on your interaction with them for improvement and further development.

      • Administer our services for internal operations, including security and business continuity, troubleshooting, data analysis, testing, research, statistical and survey purposes.

      • Comply with our legal obligations on monitoring fraud, money-laundering and reporting purposes to government authorities or financial institutions.

    3. Visitors of our website

      1. When you visit our websit e, we will process your data collected through cookies. The cookies used on our website do not collect directly identifiable personal data such as name, address, email address etc. However, certain cookies may collect information about the device used, which, when combined with other information, it becomes personal data and can indirectly identify you.

        Cookies allow us to automatically collect information about you and your online behaviour, as well as your device (for example your computer or mobile device) and browser used, in order to ensure proper functioning and security of our website. We may also use this information to collect statistics about the number of unique visits of our website and perform analytics.

        The cookies we use are necessary for the well-functioning of our website. You can set your browser to block, delete previously-stored cookies or alert you about these cookies, but some parts of the site may become inaccessible or will not function properly. For more information on what are cookies and how we use them, please consult our Cookie Policy.

      2. Contact us

        You have the option to contact us in multiple ways: through e-mail, through our contact form or phone call. For this, we will process your first and last name, e-mail address, your phone number and any other information that you willingly provide to us within the message that could directly or indirectly identify you to:

        • communicate with you;

        • provide response and support for your request, a quotation for using our services and/or negotiate the terms of the agreement with you.

  5. Legal basis for processing

    We process your personal data only when we have a valid legal basis to do so and as permitted by law. The data we collect about you will only be used for the purposes stated in this Privacy Notice, to perform our contractual obligation towards you, to comply with our legal obligations and to protect our legitimate interests in specific circumstances, as follows:

    • Performance of Contract – we will process your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. As well, if you are a card-holder or alternative payment method user making a payment to a merchant using our services to process your payment, we may process your data on the basis of the agreement that we have with the merchant and terms and conditions agreed.
    • Compliance with a legal obligation – we will process your personal data where it is necessary for compliance with a legal obligation that we are subject to. More precisely, we use your personal data to comply with anti-money laundering and counter-terrorist financing legislations requirements and any other laws applicable to our industry and requests and investigations from relevant authorities and financial institutions.
    • Legitimate Interest – we will process your data in our legitimate interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    Generally, we do not rely on consent as a legal basis for the processing of your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw your consent at any time by contacting us.

  6. Data Sharing

    We may share your data with certain third parties when it is required to provide our services in the best possible manner while complying with our obligations or enhancing the user experience.

    We will never share your personal data with any third party who intends to use it for commercial purposes, unless we have expressly informed you and you have given us explicit permission to do so. In certain circumstances described below, we will share a minimum amount of personal data as follows:

    1. Internally

      We may share personal data about you across our businesses, with our group of companies to which Prudent Pig belongs for the purpose of internal assistance and administrative matters and daily activities in line with this Privacy Notice.

      In the event of our reorganization, merger or acquisition by another company or in the event of the transfer of our business on the basis of our legitimate interest in consolidating, expanding or streamlining our business, your personal data might be shared. We will notify you if such instances happen in due course and as soon as possible.

    2. Government Authorities

      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. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

    3. Financial Institutions

      We share personal data with other financial institutions such as banks or other payment service providers to allow payment transaction between a payee and payer. These institutions are independent from our business and processing of your personal data will be subject to their Privacy Notice and Terms and Conditions.

    4. Third-party service providers

      We may engage selected service providers authorised to process personal data, who are acting as our contractors to perform support services for our business, namely – hosting, identity verification, fraud prevention, data analytics, consulting, support, marketing and advertising, data and cybersecurity, user engagement, instant messaging; as well as our business, financial, compliance and legal advisors. These third-party service providers may have access to a minimum amount of personal data, depending on each of their specific roles and purposes in facilitating and enhancing our services, and may only use it for such purposes in accordance with their contractual and confidentiality obligations.

      If you would like further information about who we have shared your data with, or to be provided with a list specific to you, you can request this by writing to dpo@prudentpig.com

  7. Storage location

    Given the global nature of our services, your personal data may be processed and stored by our us and our third-party service providers in the United Kingdom and other jurisdictions, including the European Union, as necessary for the proper delivery of our services, or as may be required by law.

    Prudent Pig, its affiliates and third-party service providers have an obligation to keep personal data protected and secured, in accordance with contractual obligations, applicable industry standards regardless of whether less stringent legal provisions apply in their jurisdiction.

    Where such recipients of data are located in third countries for which the UK Government has not issued an adequacy decision, Prudent Pig has in place contractual relationships with each such recipient that include international data transfer agreements and standard contractual clauses as approved by the UK Government or other supervisory authority where required, intended to ensure an adequate level of protection. We will always conduct rigorous due diligence to ensure there are no risks to such transfers and your personal data is protected and secured.

  8. Data retention

    Your personal data will only be stored for a necessary and strict period of time in accordance with the purpose for which it is collected and applicable laws or regulatory requirements. Generally, this means that we will retain your personal data in order to comply with our legal (e.g. anti-money laundering/counter terrorism financing legislation obliges us to hold data about our clients for at least 5 years) and contractual obligations, or to protect ourselves from any potential disputes or legal claims (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.

    Upon expiration of the applicable deadlines, your personal data will be securely deleted or anonymised. If you have any questions about our data retention policy, please contact us by the means of the following email: dpo@prudentpig.com.

  9. Your rights

    At any given time, you will have the following rights regarding your personal data processed by us. Please note, other than your right to object to us using your data for direct marketing (and profiling for the purposes of direct marketing), your rights are not absolute in case of other applicable laws. They can be summarised as follows:

    • The right to information: you have the right to be provided with information on the identity of the personal data controller, on the reasons for processing your personal data and other relevant information necessary to ensure the correct and transparent processing of your personal data.

    • The right of access: you have the right to make a request for details of your personal data and a copy of that personal data.

    • The right of rectification: you have the right to have inaccurate data about you corrected or removed without undue delay.

    • The right of erasure ("right to be forgotten"): you have the right to have certain personal data about you deleted from our records. If your requests to delete your personal data violate our legal or regulatory obligations, or the data related to the request for deletion are necessary to exercise or defend our legal claims, we may not be able to act upon your request and we will notify you of this decision.

    • The right to restriction of processing: you have the right to ask us to restrict the use of your personal data.

    • The right to data portability: you have the right to ask us to transfer the personal data you have given us to you or to someone else in a format that can be read by a computer.

    • The right to object: you have the right to object to us processing (including profiling) your personal data in cases where our processing is based on a task carried out in the public interest or where we have let you know it is necessary to process your data for our or a third party’s legitimate interests. You can object to us using your information for direct marketing and profiling purposes in relation to direct marketing.

    • The right in relation to automated decisions: you have the right to not be subject of a decision which produces legal effects which concern you or which has a significant effect on you based only on automated processing, unless this is necessary for entering into a contract with you, it is authorised by law or you have given your permission for this. Please note, we currently do not perform such processing.

    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    In order to exercise any of the above rights, please contact our DPO at dpo@prudentpig.com. Your request will be reviewed and answered within one calendar month from receipt, in accordance with regulatory deadlines. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

    We pay the utmost attention to the confidentiality of all personal data and reserve the right to verify your identity if you submit a request for personal data to avoid a potentially undesirable situation for another person to illegally exercise a right on your behalf. We may also contact you to ask you for further information in relation to your request to speed up our response.

    You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  10. Children’s Privacy

    The services of Prudent Pig are not intended or designed to attract minors. Therefore, we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 18 is using our services, we will prohibit and block such use and will make all efforts to promptly and securely delete any personal data stored with us with regard to such child. If you believe that we might have such data, please contact us by email at dpo@prudentpig.com.

  11. Contact us

    If you have any questions, comments, complaints or suggestions relating to this notice, or any other concerns about the way in which we process personal data about you, please contact our Data Protection Officer using the following details:

    Email: dpo@prudentpig.com

    Postal address:
    Prudent Pig Ltd, Data Protection Officer,
    1st Floor, 239 Kensington High Street London W8 6SN

Company number: 13030110