This Privacy Policy is an overview of how IterPay (hereinafter, "We" or "IterPay") collects, uses, and processes your personal data when you use the website (https://iterpay.net) (hereinafter, the "Website"), and when sending money to Beneficiaries (hereinafter, the "Services" or "Service").
Please read this Policy carefully, as it becomes legally binding when you use the Services. IterPay takes privacy and data protection very seriously and is committed to handling personal information with the utmost care.
If you have any questions about how we protect or use your data, please email us at iterpay@rosolutionsonline.com.
Data we collect about you
We will collect and process the following data about you:
Information you provide to us: you may provide us with information about yourself when you register to use the Service (for example, when you provide us with personal data such as your name and email address). This also includes information you provide through your continued use of our Services. The information you provide may include, but is not limited to: your name, address, email address, phone number, your Beneficiary's financial information, source of funds, source of wealth, payment details (excluding card number and secret pin), geographic location, tax identification number, and photograph;
Information we may collect about you: We may automatically collect details of transactions you make when using our Services, including the geographic location from which the transaction originates, but never your card number or secret pin. We may automatically collect technical information, including the IP address used to connect your computer to the Internet;
Information we receive from other sources: We may receive information about you from third parties we are closely working with (for example, payment service providers who are processing the payments you are making to send your transaction, providing us with your basic personal information, as well as your financial information, such as limited information about your payment card details);
Data of minors
The Services are aimed at adults over 18 years old and are not intended for children. We do not knowingly collect data from this age group. Our verification process prevents IterPay from collecting this data. If data from a child is collected without parental consent verification, it will be deleted.
How we protect your personal information
We take the protection of your information very seriously and take a number of measures to ensure it is kept secure:
Communication over the Internet between you and IterPay servers is encrypted.
Our technical security team proactively monitors abnormal and malicious activity on our servers and services.
We restrict access to your personal information to those IterPay employees who have a business reason to know such information.
Ways we use your information
We use your information:
To fulfill our obligations related to the contract entered into by the parties for the provision of Services.
To comply with applicable legal requirements.
To notify you about changes to our Services.
As part of our efforts to keep our Services safe and secure.
To administer our Services and for internal operations, including data analysis, testing, research, and statistics.
To improve our Services and ensure they are presented in the most effective manner.
To enable you to receive a refund through our Services.
Legal basis for processing
The legal basis we use to collect and process your information is as follows:
When it is necessary to enter into or perform a contract with you.
When we have a legitimate interest in doing so, provided that your rights do not override those interests.
Where you have given your consent for specific uses.
Where it is necessary to comply with our legal obligations.
Disclosure of your information
We may share your information with selected third parties, including:
Payment service providers who process your payments and/or provide the necessary payment services for the provision of Services (for example, the banks we use to receive your payments and request a credit transfer to your personal bank account).
Business partners, suppliers, and subcontractors who help us perform and deliver the Services and/or mitigate fraud.
Analytics that help us improve and optimize our site.
Our group entities or subsidiaries.
We may disclose your personal information to third parties:
Such as affiliates, business partners, suppliers, and subcontractors for the provision of Services.
If we are under a duty to disclose or share your personal data to comply with any legal obligation.
If we need to enforce the Terms and Conditions or any other applicable agreement.
If we need to protect the rights of IterPay, including sharing information with other companies and organizations for fraud protection purposes.
To help us conduct or cooperate in fraud investigations or other illegal activity when we believe it is reasonable and appropriate to do so.
To prevent and detect fraud or crime.
In response to a court order, or as required by law.
IterPay will never sell, publish, or share your information if it is not related to the above.
If you want more information, please feel free to write to us at iterpay@rosolutionsonline.com.
Sharing and storing your personal data
The Services are provided by IterPay, an entity duly incorporated in Poland. When you open an account or use the Services, your personal data will be processed by IterPay. For the avoidance of doubt, by submitting your personal data, you consent to this transfer, storage, and processing.
To provide you with our Services, we may transfer and store your data in a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff may be engaged, among other things, in fulfilling your payment order, processing your payment data, and providing support services. By submitting your personal data, you consent to this transfer, storage, and processing. We will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this privacy policy.
It may be necessary for us to transfer your data to the third parties described in section 6 who are based outside the European Economic Area. In these cases, we ensure that both we and our partners take appropriate and adequate technical, physical, and organizational security measures to protect your data.
Automated decision-making
We may use Automated Decision Making (ADM) to help combat financial crime. We may use ADM to verify that your IP location matches the information about your residence that you have provided to us, or to verify that the account holder of your payment method matches your account details.
Cookies
We use cookies to ensure the functionality and security of our website and services. As processing is necessary for legitimate interests, namely to ensure the functionality and security of the website and services, we do not require your consent for this processing.
Data retention
Given the nature of the Services, we are required to store some of your personal and transactional data beyond the closure of your account with us. We only access your data internally when necessary, and we will only access or process it if it is absolutely necessary. If you want to know more about this, contact us at iterpay@rosolutionsonline.com.
We will always delete data that is no longer required by any relevant law or jurisdiction in which we operate.
Your rights
You have the right to access the information we hold about you, which includes, subject to the applicable provisions of data protection law, the following:
Provide you with a copy of the information you have given us.
Provide you with more details on how we use your information.
Update any inaccurate, incorrect, or outdated personal information we hold.
Delete any personal information that is no longer necessary, or that is no longer subject to a legal obligation to which we are subject (IterPay has legal obligations, so it may not be possible to delete your data at the time of request. Over time, we will then be able to fulfill your request).
Where processing is based on consent, withdraw your consent to stop that particular processing.
Object to any processing based on legitimate interests, unless our reasons for undertaking that processing outweigh any harm to your data protection rights.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (for example, the prevention or detection of crime).
If you exercise any of these rights, we will verify your entitlement and respond in most cases within a month.
If you have any questions about how we use your personal information, contact us at iterpay@rosolutionsonline.com.
Third-party links
Our Services 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 for them. Please check these policies before submitting personal data to these websites.
Changes to our privacy policy
We may revise this Privacy Policy at any time without prior notice, as necessary to keep up with changes in legislation. Likewise, we may revise this Privacy Policy at any time without prior notice in order to keep up with best practices and changes in how we process personal information, as long as it is in your interest or when applicable law allows us to do so. We will post the revised version on this website and, where possible, notify you by email or push-up notification when you access your account. In all other cases, we will review this Privacy Policy in accordance with the legal requirements of the applicable law.
