Privacy Policy

Introduction

This policy describes how we collect and use data about you and when we share it with third parties. We value our relationship with you and place the highest importance on respecting and protecting your privacy. We will only process personal information in accordance with applicable law and this privacy policy.

Terms

“Paynovus“, “we“, “us“, and “our“ refer to Snowy Technologies GmbH, together with its employees, directors, successors, affiliates, and assignees use variety of tools and third party services to provide services to you (“you”, “customer”, “user”, “your” refer to users of the Service, whether in their capacity as Senders, Recipients, or visitors to our websites or apps).

Paynovus will be the data controller of all personal information you submit to us.

Data collection in public page:

When you browse our web page without logging in, we don’t hold any personal data about you, but we use a number of tools to help us maintain the website and provide the best possible experience for you.

We collect 2 types of data about you when you’re not logged in:

1) Technical performance, behavioral and affiliate data: This data includes technical logs about page performance and anonymous customer behaviour data to improve the website. This data is anonymous and cannot be tracked back to you, but is essential for us to keep our page and business up and running. Affiliate data does include customer identification number, but it cannot be traced back to you by a third party, only by Paynovus. Here’s a list of providers we are currently using:

– Google Analytics – a tool used to track aggregated customer behavior and provide insights about the system. We’re always masking your IP address, so it’s not possible to identify you.  a tool which lets developers, ops, and tech teams measure and monitor the performance of their applications and infrastructure.

-WPFC- its a wordpress plugin which we use to save cache & cookies data to make our web page more faster to our customer.

2) Marketing oriented data: This data is used for marketing purposes, including retargeting you across the web or social networks, measuring conversions, personalising ads based on your profile (e.g. country you’re visiting from to provide ads in your native language). All this data is stored in your cookies and does not contain personal identifiable information on our side. If you wish to reset this setting, please clear the browser cookies.

Data collection in product:

Once you’re logged in, you become an identifiable person to us, thus we track and keep more information about you, including your personal data. We may share your personal information with third parties if we are requested or required to do so by the police or any regulatory or government authority investigating suspected illegal activities, or upon the receipt of a court order, and such disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Paynovus rights or property. We may also provide third parties with aggregate statistical information and analytics about users of our Service, but we will make sure that no one can be identified from this information before we disclose it.

Security of your data:

We take protecting your data very seriously – we encrypt the information you provide during the transmission of the information, our internal systems are logging access to your data when/if accessed by our employees, our offices have perimeter control from unauthorized entry, we have internal IT security procedures and use best security practices to minimise risks from outside attacks, all critical systems require 2 factor authentication and/or are accessible only through internal network/VPN.

Why we need your personal data:

1) As an e-currency exchanger, we are required to reliably identify the customer before providing any exchange services and do everything in our power to prevent any anti-money laundering and fraudulent activities, for which we may need additional information and/or documentation from the customer, depending on specific cases. 2) For regular business operations and fulfillment of our Terms and Conditions agreement with you to use Paynovus services. When sending money, we need to specify who’s sending it. We may sometimes request a sender to provide more information or additional documents on a recipient. 3) To protect customers and/or our interests, we keep all communications with our clients to ensure that in case of disputes we have all available communication logs. 4) To provide better offers for you – knowing personal details about means you we can offer you a better, more personalised service and provide valuable offers. We collect 3 types of data in the product:

a) Personal and financial data required to comply with KYC (Know Your Customer), AML and CTF (Anti-Money Laundering and Combating the Financing of Terrorism) regulations and perform financial and business operations:

This data includes your e-mail, phone number, name, surname, address, nationality, date of birth, bank (electronic money payment institution) account information (including debit/credit card details), transaction history and other personal data which may help us comply with the regulation and prevent fraudulent behavior. When transferring money, we also provide some personal details to our partners (financial intermediates) to complete the transaction (including, but not limited to payment cards processor, sanctions list providers, fraud detection systems, partner banks, electronic money payment institutions).

b) Technical performance, behavioral analysis and communication data:

This data is intended to be anonymous but may include parts of personal data or user related data. We use number of tools to track technical page performance, monitor errors, page usage statistics which help us to improve our services and provide better customer experience and communicate effectively with our customers.

c) Marketing, personalization, profiling data:

We use a wide range of marketing tools to reach to our existing and potential customers. Such tools include retargeting platforms, to show relevant ads to you and/or improve your experience.

Partner selection policy

We reserve the right to include or exclude new partners to process the data in any of the categories mentioned in this policy. We take data protection seriously and always partner with companies which provide solid Data Processing Agreement (DPA) or other data protection agreements with these companies.

Profiling, segmentation and automated decision making:

We have a very wide range of customers across the world and we try to personalise the experience for them. Profiling ranges from sending marketing communication in preferred language, to new product announcements which might be useful for particular customers or providing special offers. None of our profiling activities cause legal effects for the customer, except for fraud prevention measures which we have a legal responsibility to as per Anti-Money Laundering legislation.

We always ask our customers for privacy policy consent:

If customer accepts the privacy policy we can send additional identifiers to better understand customer behavior. We’ll also send marketing communication messages using electronic channels.

Marketing communication preferences:

We communicate with our customers about new products or services, special offers and other marketing announcements. By accepting this privacy policy you agree to receive marketing communication from us using electronic methods (e-mail, app, SMS, phone calls).

Executing your rights to data:

European General Data Protection Regulation (GDPR) gives you more rights to control which data about you can be accessed by companies like us. Here’s a list of rights specified in regulation:

The data subject’s right of access. The data subject’s right to rectification. The data subject right to restriction of processing. The right to be informed. The right to data portability. The right to object data processing.

Coоkie policy:

Cookies are a small piece of information saved in your browser storage. They are used to improve the customer experience in pages and helps third party services to work properly.

Paynovus uses cookies extensively in both public page and the product. Most of the third party providers we use set cookies in customer browser to facilitate their services. Private data is never stored in cookies, only anonymous identifiers or other preferences. Data retention depends on the coоkie policy but not will not be more than 24 months.

Additional information about this policy and future changes:

We may disclose your personal information to the following parties: We may share your personal data with any member of our group or subsidiaries (i.e. any organisation we own or control) or our holding company or ultimate holding company (i.e. any organisation that owns or controls us) and any subsidiaries they own. These companies will only use your personal information to provide a service to us or to you in the same way as we can under this privacy policy.

In the event that we sell any business or assets, personal information may be disclosed or transferred to buyers or prospective buyers of our business or any of our assets as part of any such sale.

 

If you have any questions about this policy, please contact us for more information via email support@paynovus.com. We reserve the right to change this policy and inform the customers either via product or other communication means (e.g. email) 7 days before the actual change.