Privacy Policy (Europe)

Effective date: August 25, 2020

1. Introduction

PayPugs collects data about visitors, subscribers, and clients of www.PayPugs.com and our social media accounts on Facebook, LinkedIn, Twitter and Instagram.

PayPugs (“PayPugs”, “we” or “us”) data collection practices in this regard are governed by the following privacy policy ("Privacy Policy"), which explains what Personal data PayPugs collects, how we use it and who have access to that Personal data.

You have defined rights that you can use to control your privacy. PayPugs respects those rights. We want to help you exercise your rights, you will find details below on how to do so.

Throughout this Privacy Policy the term "processing" is used to cover all activities involving your Personal data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of information.

2. Definitions

“Applicable Data Privacy Laws” means data protection laws and regulations implementing the Data Protection Directive 95/46/EC and as of 25 May 2018 the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal data and on the free movement of such data, and repealing Directive 95/46/EC (Gen¬eral Data Protection Regulation) (the "GDPR").

“Personal data” is defined as any information relating to an identified or identifiable natural person.

“Controller”
Exodus Services SIA, registration number 40203003923 is the controller ("Controller") in regard to visitors’ and subscribers’ Personal data covered by this Privacy Policy.

PayPugs Capital LLС (Wyoming, US), registration number 2020-00092964, Velvet Finance Limited (UK), registration No. 11413658, is the controller ("Controller") in regard to Client’s Personal data covered by this Privacy Policy.

The Controller is a part of the PayPugs group of companies. An updated list of companies within the PayPugs group companies can be found by sending a request to [email protected].

The PayPugs group of companies has established an Intra Group Data Transfer Agreement which governs any transfer of Personal data within the group of companies.

3. The source of Personal data

PayPugs collects Personal data directly from you when you are using our websites and social media accounts.

4. Cookies

Please see Cookies policy here: https://www.PayPugs.com/cookies-policy/Cookies_Policy.pdf.

5. Why do we collect and process your Personal data in general

5.1 Provide you with information

We collect your personal data and other information when you ask for demo, or otherwise interact with us. Also, when you visit our website and social media accounts we may collect and process your Personal data in order to identify if you could be a potential client or business opportunity.

Personal data processed for these purposes mainly include:

  • Name
  • Company name (if any)
  • Email address
  • Country

The legal basis for the above processing of your Personal data is that the processing is necessary in order to fulfil our legitimate interest to provide you with information you have requested, article 6.1 f) GDPR.

5.2 Communication with you

Our websites and some of our social media accounts provide functionality for the visitor to communicate with us e.g. to ask questions, provide comments and give feedback regarding our services and business. Were you use such functionality (for example, online chat).

PayPugs will processes your Personal data for the purposes of answering your questions, communicate and handle feedback from you.

Personal data processed for these purposes mainly include:

  • First name
  • Last name
  • Company name (if any)
  • Email address
  • Phone
  • Feedback and/or comments made by you

The legal basis for the above processing of your Personal data is that the processing is necessary in order to fulfil our legitimate interest to answer questions and handle feedback from you, article 6.1 f) GDPR.

5.3 Create and managing personal PayPugs payment account

Our websites allow PayPugs clients to log in into personal PayPugs payment account. When you log in PayPugs will process your Personal data in for the purposes of creating and managing your account, identify you, create your log-in and provide you with access to your account.

Personal data processed for these purposes mainly include:

  • First name
  • Last name
  • Date of birth
  • ID/Passport, selfi-identification
  • Company name (if any)
  • Email address
  • Phone

The legal basis for the above processing of your Personal data is that the processing is necessary in order to fulfil our contract obligations under the Service agreement, the DPA and fulfil the user account agreement with you, article 6.1 b) GDPR. If you do not provide information marked with * on the website form, we will not be in a position to provide you with the requested service.

5.4 Establish, exercise and defend legal claims

PayPugs may process your Personal data for the purposes of establishing, exercising and defending legal claims e.g. in the unlikely event of a dispute.

Personal data processed for these purposes mainly include:

  • First name
  • Last name
  • Company name (if any)
  • Email address
  • Other information as necessary for the purpose

The legal basis for the above processing of your Personal data is that the processing is necessary in order to fulfill our legitimate interest to establish, exercise and defend legal claims, article 6.1 f) GDPR.

6. Length of time that we keep your Personal data for

PayPugs will retain Personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by local law to which PayPugs is subject.

We are using the following criteria to establish our retention period:

  1. as long as we have an ongoing relationship with you (either as an individual or in your capacity as employed by one of our corporate clients, suppliers or co-operations partners);
  2. as required by legal obligations to which PayPugs is subject (such as tax and accounting obligations, Financial and other regulations, etc); and
  3. as advisable in light of our legal position (such as applicable statutes of limitations).

7. Disclosure and transfer of Personal data

Group of companies

PayPugs may disclose Personal data processed to other companies within the PayPugs group in accordance with Intra Group Data Transfer Agreement.

Data processors acting on behalf of PayPugs

Moreover, PayPugs may disclose Personal data to external parties, such as vendors and service providers processing Personal data on behalf of and under the instructions of PayPugs.

Appropriate Safeguards to countries outside the EU/EEA-area

Where PayPugs transfers Personal data outside the EU/EEA, PayPugs will ensure that Standard Contractual Clauses have been entered into between the transferring PayPugs entity and the receiving external party.

Alternatively, other safeguards will be put in place prior to such transfers. You are under Applicable Data Privacy Law upon request entitled receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your Personal data during a transfer outside the EU/EEA. You can do so by reaching out to [email protected].

8. Security

We will ensure that the access to your data is accurately secured by applying appropriate safeguards, depending on the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and organizational measures to protect your Personal data against: unauthorized or accidental destruction, alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorized access.

9. Your rights

In relation to our processing of your Personal data you have, under certain circumstances, the right to exercise the following main categories rights:

Access

You may request confirmation whether or not Personal data is processed and, if that is the case, access to your Personal data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the Personal data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise.

Object to certain processing

You may object to the processing of your Personal data on the basis of a legitimate interest, on grounds relating to your particular situation and to the processing for direct marketing purposes.

Rectification

You have at any time the right to have inaccurate Personal data rectified, as well as, taking into account the purposes of the processing, the right to have incomplete Personal data completed.

Erasure

You may have your Personal data erased under certain circumstances such as when your Personal Data it is no longer needed for the purposes for which it was collected.

Restriction of processing

You may ask us to restrict the processing of your Personal data to only comprise storage of your Personal Data under certain circumstances, such as when the processing is unlawful, but you do not wish your Personal Data erased.

Withdrawal of consent

You have the right to at any time withdraw your consent to processing of Personal data to the extent the processing is based on your consent.

Data Portability

You may ask to receive a machine-readable copy of Personal data processed and ask for the information to be transferred to another data controller (where possible). This only refers to such Personal data processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you and only to the extent the Personal data have been provided to PayPugs by you (data portability).

10. Contact information

If you have any questions or concerns regarding the processing of your Personal data or wish to exercise any of your rights, please contact us on [email protected].