Last Updated: December 1, 2020
Table of Contents
- Are minors welcome?
- What types of information does Segpay Collect about you and how is it collected?
- Information Segpay collects through automatic data collection technologies.
- How does Segpay use your information?
- With whom does Segpay share your information?
- Where is your data kept?
- What rights do you have about how Segpay uses and discloses your informaiton?
- How do you exercise your rights?
- How does Segpay protect your personal information?
- Data Retention
- Contact information
- Notice for California Residents
This policy applies to information Segpay collects:
- When you apply for a trial offered by a merchant and/or Segpay processes (or attempts to process) a transaction on behalf of a merchant where you purchase or gain access to the merchant’s products and services.
- When you apply for a service of Segpay, such as the one-click purchase functionality or make use of the customer portal;
- In email, text, live chats, phone calls and other electronic messages between you and Segpay; and/or
- When you interact with Segpay’s advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
Important: Please read this policy carefully to understand Segpay’s policies and practices regarding your information and how Segpay will treat it. If you do not agree with Segpay’s policies and practices, your choice is not to use the Service and Segpay will not be able to execute the payment and complete the purchase. By accessing or using the Service, you agree to this policy and consent to Segpay’s collection, use, disclosure, retention, and protection of your personal information as described in this policy. Segpay may change this policy on one or more occasions. Segpay will consider your continued use of the Service after Segpay makes changes as your acceptance of the changes, so please check this policy frequently for updates.
1. Are minors welcome?
The Service is not intended for persons under 18-years old. You will only make purchase transactions while using the Service if (1) you are at least 18-years old and (2) have reached the age of majority where you live. Segpay prohibits all persons who do not meet the age requirements from accessing the Service. Minors must not use the Service.
Segpay does not knowingly collect any information about children, minors, or anyone under the age of majority. Nor does Segpay knowingly market to children, minors, or anyone under 18-years old. If you are under 18-years old, you must not submit information to Segpay and must leave the relevant merchant website immediately. If Segpay becomes aware that a child, minor, or anyone under 18-years old has provided Segpay with personal information, Segpay will take steps to promptly cancel that transaction.
Legal Notice: Parental control protections (including computer hardware, software, or filtering services) are commercially available that may assist in limiting access to material that is harmful to minors. You may find information about providers of these protections on the Internet by searching ‘parental control protection’ or similar terms. If minors have access to your computer, please restrain their access to sexually explicit material by using any of the following products, which Segpay provides for informational purposes only and does not endorse: CYBERsitter | Net Nanny | CyberPatrol | ASACP.
2. What types of information does Segpay collect about you and how is it collected?
Segpay may collect several types of personal information from as a user of the Service, which is information by which you may be personally identified, including your first name, last name, postal address, telephone number, browser information, IP address, email address or any other information that Segpay collects that is defined as personal or personally identifiable information under law (‘personal information’).
Segpay collects this information:
- Directly from you when you provide it to Segpay.
- Automatically as you navigate through the Service. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, from merchants and Segpay’s business partners, such as ThreatMetrix (for collection of browser information).
Legal Basis Personal Information Collecting Through Services. The information we collect in relation to the Services is information necessary in order to perform the contract that is between you and the merchant (for the purchase of goods/services). On this basis Segpay is considered to be undertaking lawful processing as set forth under applicable data protection laws. As part of our Services, we will inform you when your trials with merchants expire. These activities are considered relevant and appropriate in relation to your relationship with Segpay. The processing of your personal information for this purpose is based upon the lawful ground of carrying out a legitimate interest.
3. Information Segpay Collects through Automatic Data Collection Technologies
As you navigate through and interact with the Website or the Service, Segpay may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and Internet connection, including your IP address, operating system, and browser type.
- Information about your mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number. Segpay also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information Segpay collects automatically is statistical data and does not include personal information, but Segpay may keep it or associate it with personal information Segpay collects in other ways or receives from third parties. This information helps Segpay to improve the Website, the Service, and to deliver a better and more personalized service, including by allowing Segpay to:
- Estimate the Website’s and the Service’s audience size and usage patterns.
- Store information about your preferences, thus allowing Segpay to customize the Website and the Service according to your individual interests.
- Recognize you when you return to the Website.
- Continually personalize electronic payment services.
- To detect and mitigate fraud.
The technologies Segpay uses for this automatic data collection may include:
- Flash Cookies. Certain features of the Website or the Service may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website or the Service. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, you can access your Flash management tools from Adobe’s website.
- Web Beacons. Pages of the Website (and Segpay’s emails) may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Segpay, for example, to count users who have visited those pages (or opened an email) and for other related website statistics (for example, verifying system and server integrity). To learn more about web beacons, visit www.allaboutcookies.org/web-beacons/.
Segpay does not collect personal information automatically, but it may tie this information to personal information about you that Segpay collects from other sources or you provide to Segpay.
Segpay does not control third-party tracking technologies or how third parties’ use them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
4. How does Segpay use your information?
Segpay may use the personal information that it collects about you or that you provide to Segpay, including any personal information:
- To present the Website and its contents to you and to improve the Website.
- To contact you and to provide you with information, products, or services that you request from Segpay.
- To provide the Services to you and to provide customer support.
- To continually personalize and offer the Services Segpay provides (such as one-click purchase functionality);.
- To provide the Services to merchants and to carry out its obligations arising out of the agreements with such merchants and to process and complete purchase requests and other transactions, and send you related information, including purchase confirmations.
- To send transactional messages and provide you with notices, respond to your inquiries and provide customer support [about your Purchase ID (s)), including expiration and renewal notices].
- To send you any transactional emails related to any trials joined and/or services from merchants selected by you or from similar merchants and related marketing thereto.
- To resolve any disputes between merchants and you, such as refund requests or chargebacks.
- To manage risk, or to detect, prevent, or remediate fraud or other potentially prohibited or illegal activities.
- To enable the processing of a refund for a payment transaction executed previously.
- To allow Segpay’s clients to provide customer service and fulfill their obligations to you.
- To investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities.
- To comply with relevant laws and regulations, including the retention of financial information and transactions and the detection and prevention of criminal activity.
- To comply with legal proceedings and or requests from government/ supervisory bodies and/or payment schemes (SEPA, Visa, Mastercard, Diners, American Express; depending upon your chosen payment method and the governing scheme of such payment method).
- For profiling purposes (see below*).
Your browser information and location are collected in order for Segpay to establish the best available language for you, and your preferred payment options or currencies based on your location, your risk profile will also be generated to ensure that any type of fraud is mitigated as much as possible. Transactions may be declined as a result of this profiling; however, you can contact Segpay if you feel you were declined in error. This information is necessary for Segpay establishing and maintaining a relationship with you. Segpay will safeguard your rights, freedoms and legitimate interests. However, any decisions made on your (risk) profile are not solely based on automated processing. You will have the right to obtain any human intervention, to contest any automated decision and express your point of view.
5. With whom does Segpay share your information?
Segpay may disclose personal information that it collects, or you provide as described in this policy:
- To Segpay’s subsidiaries and affiliates.
- To Segpay’s affiliate merchant banks, credit card associations and other payment method providers (depending upon the payment method chosen by you to make the payment with) as required to process a transaction and provide services to you.
- To Segpay’s clients (merchants) from which you have purchased a product or service online using the Service. Segpay receives, stores, and forwards to its clients all information necessary for its clients to ship your product to you or to provide requested services and to contact you if necessary.
- To contractors, service providers, and other third parties Segpay uses to support its business, which include the support in relation to server hosting, security/ protection, gateway facilitation, fraud prevention, anti-money laundering and sanction screening, customer support ticketing systems and corporate email. These parties are bound by contractual obligations and processing agreements (or other safeguards as set forth under section 6 of this Policy) to keep personal information confidential and use it only for the purposes for which Segpay discloses it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all Segpay’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Segpay about the Service’s or the Website’s users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by Segpay when you provide the information.
- With your consent.
Segpay has made arrangements with such parties to ensure the proper security of your personal information in compliance with applicable data protection laws. In any case, when the data transfer is not necessary for the execution of the payment transaction or any other purpose as provided in this Policy, Segpay will inform you of the purpose of processing and the identity of the potential third parties so that you may permit or refuse the transfer depending on its purpose. In general, the third-party providers used by Segpay will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us and the merchant. These parties are not only based within the European Economic Area. Please be referred to the next section 6.
Segpay may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply the terms of service and other agreements.
Segpay may disclose aggregated information about its users (but only after anonymization), and information that does not identify any individual, without restriction. Segpay does not share your personal data with third parties without obtaining your prior consent, unless the transfer is necessary for execution of the payment you initiated or requested, in which case you will be informed before such information is shared (through this Policy). Segpay does not sell or rent your personal data.
6. Where is your data kept?
Your personal information may be transferred outside of your country or region (such as the European Economic Area), to other countries including the United States, which may have data protection rules that are different from those of your country. This could happen if you make a purchase at a merchant that is not based within your country or region or if any third party Segpay uses is based outside of your country or region. For any US non-residents: If you are accessing the Service, please be aware that your information may be transferred to, stored, and processed in the United States where Segpay’s servers are located and Segpay’s central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. To comply with EU data protection laws around international data transfer, Segpay only allows third parties outside the European Economic Area to process your personal data if they apply the European Commission’s Standard Contractual Clauses (Article 46.2(c) GDPR). For more information on where and how the relevant document may be accessed or obtained, please contact us. By using Segpay’s services, you acknowledge that your information may be transferred to Segpay’s facilities and those third parties with whom Segpay shares it as described in this Policy.
Appropriate safeguards. Segpay will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal information remains protected to the standards described in this Policy. Segpay’s affiliated companies in the US are bound to Standard Contractual Clauses. For any other third parties, Segpay will either ensure that: (i) the transfer is permitted as their country of residence is designated by competent authorities as providing an adequate level of protection, similar to your rights under European data protection legislation; or (ii) other sufficient measures are put in place to ensure that such third party provides the appropriate safeguards, such as Standard Contractual Clauses which shall include the ability for you to exercise your rights as set forth in the next section 7. As part of such appropriate safeguards, such parties that receive your personal information (if you pay with card) will at all times adhere to the Payment Card Information Data Security Standards as set by the card schemes.
7. What rights do you have about how Segpay uses and discloses your information?
Segpay provides you the ability to exercise certain controls and choices regarding its collection, use, and sharing of your personal information at all times. In accordance with local law, your controls and choices include all of the following: access your personal information, rectification or erasure (right to be forgotten) of personal information and objection to such processing. Further, you retain the right to request restriction of processing (if for instance you objected to our processing or you contest the accuracy of the personal information).
Finally, you may also contact Segpay and exercise your right to data portability. This means you may receive your personal information which you have provided to Segpay, giving you the right to transmit this to a third party, provided that the processing by Segpay has been carried out by automated means and such transfer is technically feasible (right to data portability).
Specific to Segpay’s profiling activities, please note your right to object thereto. However, any decisions made on your (risk) profile are not solely based on automated processing. If this is the case though, you retain the right to not be subject to such decisions solely based on automated processing.
Segpay will inform you about any rectification or erasure of your personal information or restriction of processing carried out pursuant to your request. In the event Segpay does not conform to your request, for justifiable reasons, Segpay will inform you without delay and clarify the reasons for not taking action. You may then exercise your rights under the next paragraph.
The right to lodge complaints
Besides any other remedies given by you under law, you will have the right to redress and to lodge a complaint with the data protection authorities in your country or in the Ireland (if you are an EU resident) or in the United Kingdom (if you are a UK resident), if you feel that Segpay’s processing of your personal information infringes applicable data protection laws. Please visit the website of the data protection authorities in your country (for the EU go here: https://forms.dataprotection.ie/contact for the UK go here: https://ico.org.uk/concerns/) to obtain more information on how the complaint procedures work.
8. How do you exercise your rights?
9. How does Segpay protect your personal information?
Segpay will process any received personal data in accordance with the requirements of applicable data protection legislation, including the European General Data Protection Regulation. Segpay has implemented adequate technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, change, and disclosure. All information you provide to Segpay is stored on its secure servers behind firewalls. Segpay encrypts all payment transactions using TLS technology as required by PCI standards.
No Security Guarantees. The transmission of information over the Internet is not completely secure. Although Segpay does its best to protect your personal information, Segpay cannot guarantee the security of your personal information transmitted to the Service. Any such transmission of personal information is at your own risk. Segpay is not responsible for circumvention of any privacy settings or security measures contained on the Service. Nor does Segpay guarantee against all unauthorized disclosure, alteration, or destruction of personal information.
10. Data Retention
Your personal information will not be stored longer than necessary for the provision of the Service to the merchant or to you and for as long as required by applicable law. The exact retention period is determined on the basis of the following criteria: the continued use by you of the Service for any other trials or subscriptions you select from merchants and to provide you with support for any future purposes (for instance for new trials or subscriptions of merchants). Segpay’s retention of your personal information will ensure a continuous and improved use of the Service and your management of trials and subscriptions history. In order to comply with applicable anti-money laundering (AML) laws, we are required to hold transaction records, including your personal information, also after the business relationship with the merchant has ended. You maintain the right to require erasure of your personal information. If you exercise your right to erasure, we will assess which data is required to ensure AML compliance. Any other data will be deleted.
Segpay will post any changes it makes to this policy on this page. If Segpay makes material changes to how it treats your personal information, Segpay will notify you by email to the email address that Segpay has on file for you or through a notice on the Website homepage. This policy identifies when Segpay last updated it at the top of the page. You are responsible for making sure Segpay has an up-to-date active and deliverable email address for you, and for frequently visiting the Website and this policy to check for any changes.
12. Contact Information
To ask questions or comment about this policy and Segpay’s privacy practices, you can reach Segpay at:
|Segregated Payments (Ireland) Ltd|
Carrick House, 49 Fitzwilliam Street
|Segregated Payments Limited|
71 Blanche Lane
South Mimms, EN6 3PA
220 Hillsboro Technology Drive, Suite 130,
Deerfield Beach, FL 33441
(+1) 954 414 1610
(+353) 1 513 3337
13. Notice for California Residents
The privacy notice for California residents is available here as a supplement to this policy.