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Privacy Policy

This Privacy Policy describes the ways in which we collect information from you and what we may use it for, in accordance with the new data protection law, GDPR.

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What data do we collect from you?

Information you give Us

  • You may give Us information about you by filling in forms on Our sites or by corresponding with Us by phone, e-mail or otherwise. This includes information you provide when you register to use Our sites, subscribe to Our services, place an order or transact on Our sites or report a problem with Our sites. The information you give Us may include your name, address, date of birth, contact details including e-mail address and phone number, employment details, financial and credit information.​​

  • You may give Us information relating to beneficiaries, shareholders, trustees and directors to enable us to deliver Our services. This may be through filling in forms on Our sites or by corresponding with Us by phone, e-mail or otherwise. You must obtain appropriate consent before disclosing such information to Us. The information you give Us may include their name, address, date of birth, contact details including e-mail address and phone number, financial and credit information.

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Information We collect about you.

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;​

  • Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our sites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Our customer service number.
     

Information We receive from other sources.

  • We may receive information about you if you use any other websites We operate or other services We provide. This data may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Where this is the case We will ensure this will be in full compliance of the Regulation.

 

How do we use your data?

For our operation as a bank and to provide banking and financial services including:

  • To operate bank accounts, issue eMoney, make payments, to comply with obligations to our card partner and let you use all these services and to allow you to participate in interactive features of our service when you choose to do so;​

  • To ensure our websites, content and services are as effective and relevant as possible and give you the best experience they can;​

  • To administer our business, including troubleshooting, data analysis, testing, research, statistical and survey purposes and to keep our business, websites, bank accounts and our systems safe and secure;​

  • To ensure that we comply with the law and regulations, for regulatory purposes generally as well as to help detect or prevent fraud or other crimes, and for tax, legal, reporting and auditing obligations. This means that the personal data that you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime;​

  • In case we need to check we have carried out your instructions correctly or to resolve queries or issues;​

  • To assess if you are suitable to work with or for us.​

  • We process your information for the purposes set out above on the following grounds: given our legitimate interest in providing banking and financial services, in preventing fraud and money laundering and to verify identity, in order to protect ourselves, operating and improving PayrNet and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date.

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To carry out our obligations arising from any contracts entered into between you and us;

  • We process your information for the purposes set out above on the following grounds: where it is necessary for the adequate performance of contracts with you and to take steps requested by you prior to you entering into contracts with us. Before we provide services to you we are required to carry out checks for the purposes of preventing fraud and money laundering and to verify your identity.

 

To operate our business and to provide information about you to partners and businesses that integrate to us through APIs that you choose to integrate with;

  • We process your information for the purposes set out above on the following grounds: your consent to do so where you choose to share your information with our partners and any other third parties and where it is necessary for the adequate performance of contracts with you and to take steps requested by you prior to you entering into contracts with us where our partners share it with us and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date.

 

To provide information, products and services that are requested from us, or other products and services we offer or our business partners offer or to provide and to notify you about changes to our services;

  • We process your information for the purposes set out above on the following grounds: given our legitimate interest in undertaking activities to offer you products or services that may be of interest to you or that you have expressed an interest in hearing about, given our legitimate interest in providing banking and financial services, operating and improving PayrNet and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date.

 

To measure or understand the effectiveness of any functionality or access to, or the commerciality of, any products or services we offer or to which we provide access and we use analytics and search engine providers to assist us in the improvement and optimisation of our websites, our apps and our business generally.

  • We process your information for the purposes set out above on the following grounds: given our legitimate interest in operating and improving PayrNet and providing eMoney and related payment services.

 

As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with other data held, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making and if you want to know more please contact us using the details below.

 

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or to employ you, or we may stop providing existing services to you.

 

A record of any fraud or money laundering risk will be retained by fraud prevention agencies and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details below.

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Who do we share your information with?

With our affiliates to ensure we can do the things set out above in the section “How do we use your information?”;

 

With business partners, suppliers and subcontractors, with companies, organisations or individuals outside PayrNet for the performance of any contract we enter into with them or you or for the uses set out in the section “How do we use your information?”;

 

Other third parties where you ask us to, including with our partners, those who have integrated with PayrNet through the Railsbank API or in connection with banking and financial services we offer;

 

If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to prevent fraud and money laundering or in order to enforce or apply any agreement with you or our suppliers, to protect the rights, property or safety of PayrNet, our customers or others. This includes:

  • Exchanging information with the Financial Services Compensation Scheme and with other companies and organisations for the purposes of fraud protection, money laundering prevention and credit risk reduction

  • With tax authorities;

  • With the police and other law enforcement bodies;

  • With UK and European financial services regulators;

 

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual) and non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising and other business purposes;

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Where do we store and process your information?

We process your information and store it on servers managed by our hosting providers and / or our platform provider Railsbank (please refer to the privacy policy of Railsbank Technology Limited: https://www.railsbank.com/privacypolicy).

 

Those servers are located across a number of secure data centres in the EEA. Our server / platform environment is highly secure and there is very limited personnel access. Any information will be encrypted “at rest” (in other words, on being stored).

 

We try to ensure that we do not send your information outside the EEA. However, this is not possible in all cases:

  • In relation to a very small number of our suppliers, your information may be transferred to, and stored at, a destination outside the EEA as well as processed by staff operating outside the EEA who work for them. We often rely on the EU-U.S. and Swiss U.S. Privacy Shield Framework to safeguard the transfer of your information outside the EEA. We will ensure that suitable safeguards are in place before your information is transferred outside the EEA as required by law and we will take all steps reasonably necessary to ensure that information about you is treated securely and in accordance with this notice.Similar safeguards are applied by fraud prevention agencies where they have had access to your data in accordance with this privacy policy, when they transfer your personal data outside of the EEA.​

  • If you are outside the EEA and make payments or send messages, or you are in the EEA and make payments or send messages outside the EEA, we may process payments through other institutions and payment systems. They may have to process and store information about you in connection with their own regulations; please note that the standards to which they adhere may not be as stringent as those in the EEA.

 

Unfortunately, the transmission of your information via the Internet can never be 100% secure. Although we will do our best to protect your information, we cannot guarantee the security of information about you transmitted to us and so 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 unauthorised access.

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User rights

Accessing information about you:

  • You may access information held about you.​

  • Your right of access can be exercised by emailing PayrNet at support@payr.net.
     

Managing your information:

  • To provide outstanding customer service we need accurate customer information. You can help by informing us whenever your circumstances change.

  • If you wish to update information about you which is inaccurate or incorrect, please email PayrNet at support@payr.net

  • We may need to ensure that your information is accurate and correct and this may involve a number of further steps.

 

Deleting your information:

  • Generally, we will store your information for six years but in certain circumstances, including through regulatory requirements, we may have to store this for a longer period. Please note that fraud prevention agencies are permitted to hold your personal data for different periods of time and if you are considered to pose a fraud or money laundering risk your data can be held for up to six years.

  • You may request that we delete your information and we will do so but:

  1. only if we do not need to retain it for any of the matters set out in the section “How do we use your information?” above;

  2. your information may be impossible to permanently delete and where this is not possible we will put that information beyond reasonable use;

  3. your information which you have shared with others (e.g. on our websites) may remain publicly available;

  4. please note that your information which you have transmitted to others, e.g. Marketplace partners, will be subject to the privacy policies of those others.

 

Objecting to or restricting use of your information:

  • You can ask us to stop using all or some of your information or to limit our use of it by emailing PayrNet at support@payr.net

  • We will do so but:

  1. only if we do not need to retain or use it for any of the matters set out in the section “How do we use your information?” above;

  2. your information which you have shared with others (e.g. on our websites) may remain publicly available;

  3. please note that your information which you have transmitted to others, e.g. Marketplace partners, will be subject to the privacy policies of those others.

 

Transferring your information:

  • You can ask to have transferred elsewhere information about you that you have provided to us by filling in this form.
    We will do so but:

  1. we may also need to retain it for any of the matters set out in the section “How do we use your information?” above;

  2. we may be restricted from doing so for the same reasons.

  • You have the right to lodge a complaint with the Information Commissioner’s Office (go to https://ico.org.uk/).

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Other​

Updates

  • This notice may be updated from time to time. Any updates we make to this notice will become effective immediately (and we will send them by email to customers who have provided us with an email address).

 

Contact:

  • if you have any questions about this notice or suggestions on any ways it can be improved, please let us know at support@payr.net or by getting in touch.​

  • for the purposes of GDPR, the data controller is PayrNet Limited company number 09883437 and we have our registered office at Kemp House, 152 City Road, London, United Kingdom, EC1V 2NX. For further information, please refer to the privacy policy of PayrNet Limited (a wholly owned subsidiary of Railsbank) at: https://www.railsbank.com/privacypolicy.

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