Paythru adheres to the GSMA privacy principles
This website (“website”) is operated by Paythru Limited (“Paythru”, “us” or “we”) and we are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of data protection legislation, the data controller is Paythru Limited of 5th Floor, 14-16 Dowgate Hill, London, EC4R 2SU.
Personal and non-personal information
Personal information is information that can be used to uniquely identify a person. We also collect non-personal information or may anonymise personal information in order to make it non-personal. Non-personal information is information that will not allow a specific individual to be identified. We may collect, store, use, transfer and disclose non-personal information for any purpose; for example, the use of aggregated transactional information for commercial purposes.
Information we collect from you
We will collect and process the following data about you:
- Information you give us. This is information about you that you give us by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you fill in a form on the website, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number. If you give us information on behalf of someone else, you confirm that you have given them the information set out in this notice and that they have given permission for us to use their information as set out in this notice.
- Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, 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 site (including date and time), page response times, and download errors.
Uses made of the information
Processing grounds we rely on
- We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you (for example, to provide you with any products and/or services which you have requested);
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (for example, undertaking analysis and research for the purposes of improving our website user experience); and
- Where we need to comply with a legal or regulatory obligation (for example, equal opportunities monitoring).
Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us by emailing firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data.
We use information held about you in the following ways:
Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to respond to any query or request you have put forward to us;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep our site safe and secure;
Disclosure of your information
We will not disclose your personal information to third parties except in these extenuating circumstances:
- If Paythru or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Where we store your personal data
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 unauthorised access.
You have the right to object to how we use your personal information. You also have the right to see what personal information we hold about you. In addition, you can ask us to correct inaccuracies, delete or restrict personal information or to ask for some of your personal information to be provided to someone else. To make enquires for further information about exercising any of your rights in this Privacy Notice, please contact us at email@example.com.
You are entitled to exercise any of the following privacy rights:
- Right to object: You can object to our processing of your personal information. Please contact us as noted below, providing details of your objection.
- Access to your personal information: You can request access to a copy of your personal information that we hold, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making.
- Right to withdraw consent: If you have given us your consent to use your personal information to send you marketing emails, you can withdraw your consent at any time by clicking the “unsubscribe” link in any marketing email which you receive.
- Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
- Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
- Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
- Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
- Make a complaint: You can make a complaint about how we have used your personal information to us by contacting us as noted below, or to a supervisory authority – for the UK this is the Information Commissioner’s Office, at https://ico.org.uk/.
Please make all requests to exercise your privacy rights in writing to our DPO at firstname.lastname@example.org. We are required to verify your identity in order to process your request and may ask you to provide valid identification documents to allow us to do so.
We will not make any charge for responding to any request from you to exercise your privacy rights, and we will respond to your requests in accordance with our obligations under data protection legislation.
Third party websites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. 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.
A cookie is a small file of letters and numbers that we store on your computer. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
- Analytical/performance They allow us to recognise and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. This is statistical information and does not identify any individual.
- Functionality These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
If you wish, you can set your browser to notify you before you receive a cookie so you have the chance to accept it and you can also set your browser to refuse to receive or send all cookies. The website www.allaboutcookies.org contains step-by-step guidance on how cookies can be switched off by users. Please be aware that if you do not accept cookies our website may not function correctly.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
We may also hold your personal information for longer where it is necessary to do so for the management of any active or potential legal proceedings, to resolve or defend claims, and for the purpose of making any necessary remediation payments.