This Privacy Notice applies to the use of our Website & Mobile Application
We, the team at EPG Financial Services Ltd, strongly value our own privacy – and therefore are committed to protect your personal data (i.e. information that identifies you as a natural person) as though it is our own.
This Privacy Notice describes our practices relating to the personal data of visitors of https://paylado.com and make use of our online facilities, including the visitors and use of our paylado mobile application (collectively referred to as our ‘Digital Services’). For all our services, the data controller — the company that’s responsible for your privacy — is EPG Financial Services Ltd (‘EPG’, ‘us’, ‘we’), a limited liability company incorporated under the Laws of Malta, with its address at Level 4, The Plaza Commercial Centre, Bisazza Street, Sliema SLM 1604, Malta. EPG is licensed and regulated by the Malta Financial Services Authority (‘MFSA’) as a financial institution licensed to issue electronic money under the 3rd Schedule to the Financial Institutions Act (Chapter 376 of the Laws of Malta) (the ‘Licence’).
One of your rights under Applicable Data Protection Law, particularly Regulation [EU] 2016/679, or as it is otherwise known, the GDPR and that Data Protection Act, Chapter 586 of the Laws of Malta - is that you must be informed when your personal data - also known as personal information - is processed (collected, used, stored) by any organisation. You also have the right to know the details and purpose of that processing.
We assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this Notice.
Information We Collect
Most of the personal information which we may collect about you during the course of your use of our Digital Services is given to us only if you choose to give it to us.
Such personal information may be requested from you when you fill in a field (e.g. to create your e-money wallet account, sign up for our newsletter or fill in any other form with your questions and comments or any other form or application downloaded through or from EPG’s Digital Services. If you send us emails, then the personal data we process will depend on what you send us in the email.
We normally process the following categories of personal information:
- External Data, primarily information that uniquely identifies you; including your Name & Surname; date of birth; age; email address; billing address, government issued identification document and picture; your mobile phone number;
- Internal Data, primarily information used to authenticate your use of our Digital Services; including your username, passwords;
- Social Data, primarily information about your educational or professional career; including your occupation;
- Financial Data, primarily information the identifies your financial account and transactions, including your Card primary account number; card expiry date; CVC details (card security code); account numbers; bank and/or issuer details;
- Tracking Data, primarily information about a device that you use when you use our Digital Services, such as your IP address.
Check out the next sections to understand how and why we use this information.
Some other information is given to us because you accessed our Digital Services (e.g. logs, recorded through cookies). This is explained in the Cookies section below.
How & Why We Use Your Information
We use your information in a number of different ways — what we do with it then depends on the information and the purpose for which we collected.
For some of the uses of your personal data (as described below) there is a legal basis under applicable data protection laws for us to use such personal data without having obtained your consent.
This includes, for example, where it is necessary for us to use the information to perform a contract with you or take steps at your request prior to entering into a contract with you, such as to process your order, provide customer-care and support services to you.
It also includes circumstances (such as we have described below) where we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests.
The relevant legal bases are set out in Article 6(1) of the GDPR, and are being replicated hereunder for ease of reference:
- You have given consent to the processing of your personal data for one or more specific purposes;
- The processing is necessary for the performance of a contract to you are party or in order to take steps at your request prior to entering into a contract;
- The processing is necessary for compliance with a legal obligation to which the controller is subject;
- The processing is necessary in order to protect the vital interests of the data subject or of another natural person;
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- The processing is necessary for the purposes of the legitimate interests pursued by the controller
We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data. We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
As a guide:
- we will keep your personal data while your account with us is active (if you have an account) or until such time as you ask us to stop communications with you, unless we need to keep the data for longer as specified below;
- we may keep your personal data for a period of five (5) years, unless requested by our supervisory authority or other authority to keep the relevant records for a longer period up to ten (10) years, in order to comply with our obligations under the Prevention of Money laundering and Funding of Terrorism Regulations (S.L. 373.01);
- we may also keep for a period no longer than ten (10) years your personal data relating to your transactions history in order to comply with our obligations under the Companies Act (Chapter 386 of the Laws of Malta) as well as with Tax/VAT reporting requirements;
- finally, we may keep your personal data to defend or initiate a legal claim until the rights to be claimed by EPG are prescribed by law;
- in exceptional circumstances, we may keep your personal data for the periods ordered pursuant to an order issued by a court or any other relevant public authority.
The tables below set this out in detail, showing what we do, and why we do it.
- External & Social Data
Purpose Legal Basis (GDPR) To provide you with our e-Wallet services We’ve got to do this to perform our contract with you to your best satisfaction [Art.6(1)(b)] & to comply with our obligations arising from law [Art. 6(1)(c)] Fraud prevention & detection We’ve got to do this to comply with our obligations arising from law [Art. 6(1)(c)] Provide customer service and support We’ve got to do this to perform our contract with you to your best satisfaction [Art.6(1)(b)] To send you service messages by text or e-mail We’ve got to do this to perform our contract with you to your best satisfaction [Art.6(1)(b)]
- Financial Data
Purpose Legal Basis (GDPR) To provide you with our e-Wallet services We’ve got to do this to perform our contract with you to your best satisfaction [Art.6(1)(b)] & to comply with our obligations arising from law [Art. 6(1)(c)] Fraud prevention & detection We’ve got to do this to comply with our obligations arising from law [Art. 6(1)(c)]
- Internal Data & Tracking Data
Purpose Legal Basis (GDPR) Improve our website and set default options for you (such as language and currency) We’ve got to do this to give you the best possible customer experience [Art.6(1)(f)] Protect our website We’ve got to do this to comply with our obligations arising from law [Art. 6(1)(c)] Provide customer service and support We’ve got to do this to perform our contract with you to your best satisfaction [Art.6(1)(b)] To send you service messages by text or e-mail We’ve got to do this to perform our contract with you to your best satisfaction [Art.6(1)(b)]
We also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis, improving our site and app, and developing new products and services. We also share this anonymised information with third parties – but don’t worry, they cannot identify you.
You enjoy several rights relating to your personal information:
- The right to be informed about how your personal information is being used;
We need to be clear with you about how we process your personal data. We do this through this Privacy Notice, which we will keep as up to date as possible.
- The right to access the personal information we hold about you;
To process your request, we will ask you to send us proof of identity so that we can be sure we are releasing your personal data to the right person.
- The right to request the correction of inaccurate personal information we hold about you;
We appreciate feedback from you to ensure our records are accurate and up-to-date.
- The right to request that we delete your data, or stop processing it or collecting it;
You can ask us to delete your personal data; however, this is not an absolute right.
In spite of a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation (for instance, we are required by personal data for VAT reporting purposes); and (ii) in relation to the exercise or defence of any legal claims.
When you ask us to delete your personal data, we assume that you do not want to hear from us again. To ensure that we do not send you any special offers in the future (for example, if we purchased your details from a third party list), we will retain just enough of your personal data solely for suppression purposes.
Other than as described above, we will always comply with your request and do so promptly. We would carry out our best efforts to notify any third parties with whom we have shared your personal data about your request so that they could also comply.
- The right to stop direct marketing messages;
- The right to object to certain processing based on legitimate interest;
You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated means.
- The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;
- The right to withdraw consent for other consent-based processing at any time;
- The right to request that we transfer or port elements of your data either to you or another service provider;
You have the right to move, copy or transfer your personal data from one organisation to another. If you do wish to transfer your personal data we would be happy to help.
If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation.
Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the personal data we provide.
When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.
- The right to complain to your data protection regulator — in Malta – the Information and Data Protection Commissioner (IDPC)
We will carry out our best efforts to process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your personal data in electronic format or hard copy.
If we consider the frequency of your requests as being unreasonable, we may refuse to comply with your request. In those circumstances, if you disagree, you can complain to the data protection authority – in Malta, the Information and Data Protection Commissioner.
Please appreciate that the rights must be exercised within some limitation – for example, if you ask us for information we can only give you what relates to you and not what relates to other persons. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification (we would not want to disclose information to the wrong person). Unreasonable requests may be subjected to a reasonable fee or refusal to respond.
What are cookies?
A cookie is a small text file (typically numbers and letters) that is downloaded onto ‘terminal equipment’ (e.g. your computer or smartphone) when you (or someone else) access a website using that device. Cookies are then sent back to originating website on each subsequent visit – and they are useful because they allow a website to recognize a user’s device and store some information about your preferences or past actions.
Some cookies are needed for the sole purpose of carrying out the transmission of a communication over an electronic communications network - others may be necessary for the provision of a service over the internet, in which case they have to be used.
Other cookies may be desirable to improve your experience, in which case we will ask you for your consent to use them.
What cookies do we use?
We use only two (2) types of cookies:
Necessary. Those are the cookies which are necessary to provide you with the services that you have requested;
Functional. Those are the cookies that are used to recognise you and remember your preferences and settings when you return to our website. This allows us to improve your navigation experience. For instance, through functional cookies we will be able to establish your location in order to ensure that you access the homepage of our website in your preferred language.
You can configure your browser so that you are informed when a cookie is set or can block the setting of cookies altogether completely. If you disable some cookies, please be aware that some of the features of our service may not function correctly.
How do you change your cookie settings?
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
Other Passive Information which we collect
Apart from the information you provide us with when using our Website, other information is passively collected from you (without you actively furnishing such information) when you navigate through the website. We use various technologies and navigational data collection methods to gather such passive information for various reasons, for example to track how many visitors access our website, the date and time of their visit, the length of their stay and which pages they view. The passive information also aids us to determine which web browsers our visitors use and the address from which they accessed our website – for instance if they connect to our Website through clicking on one of our banner ads. This technology does not identify you personally.
Such passively collected information may be used and combined to improve our services to website visitors, customise the website based on your preferences, compile and analyse statistics and trends of our visitors and their use of the sites operated by us and our related entities or subsidiaries. Together with our related entities and subsidiaries we will use this information and share it with third parties to improve the content, functionality and administration of our websites, to better understand our customers and markets, and to improve our products and services.
We assure you that, unless you have consented, such passive information shall not be combined with personally identifiable information collected elsewhere by our website or respective sites operated by our related entities or subsidiaries.
In any case, we never transfer your personal data to advertising companies. You may withdraw your consent at any time by choosing needed responses within your settings.
Security of Your Personal Data
Security of your personal data is very important to us.
EPG shall implement and maintain, at all times, appropriate organizational, operational, managerial, physical and technical measures to protect your personal data and any other data against accidental, unauthorised or unlawful destruction, loss, alteration, disclosure or access so that all processing is in compliance with Applicable Data Protection Laws and written instructions, especially where the processing involves the transmission of data over a network. These measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation.
Technical safeguards shall include all technical security controls defined or indicated by EPG, following the recommendations as laid out in ISO/IEC 27000 series (‘Information Security Management Systems (ISMS) standards’, or equivalent). Access to Personal Data shall be limited to authorised and properly trained personnel with a well-defined “need-to-know” basis, and who are bound by appropriate confidentiality obligations.
Where it’s appropriate, our Website uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.
You may complete a registration process when you sign up to use parts of the Digital Services. This may include the creation of a username, password and/or other identification information. Any such details should be kept confidential by you and should not be disclosed to or shared with anyone.
Where you do disclose any of these details, you are solely responsible for all activities undertaken where they are used.
Whenever you create a password, then to protect your account you should choose a strong password, meaning it should be lengthy and include a mixture of letters and numbers with mix of CAPS.
All necessary precautions are taken to prevent loss and alteration of any data, to prevent unauthorised access to EPG’s I.T. environment, to prevent introduction of viruses to EPG’s systems, and to prevent improper access to EPG’s I.T. environment and Confidential Information. We do our best to keep the information you disclose to us secure. However, we can't guarantee or warrant the security of any information which you send to us.
Security measures which have implemented to secure information transmitted over our website or stored on our systems include the following:
- Use of secure network devices;
- Use of secure servers;
- Use of firewalls;
- Performance of ongoing vulnerability and penetration tests;
- Use of encryption;
- Restricted access at data centres only to authorised personnel;
- Physical access controls at data centres;
- Information access controls;
- Use of back-up systems;
Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.
Relevant Supervisory Authority
Given that EPG is operative in more than one European Union Member State, by virtue of the passporting of its Financial Institutions licence, EPG confirms that the place of its central administration in the European Union, and thus its main establishment, as being located within Malta. To this effect, EPG recognises the Information and Data Protection Commission (http://idpc.gov.mt) in Malta to be the supervisory authority for the main establishment as the lead authority. This notwithstanding, EPG shall, in accordance with its obligations at law, cooperate with the other authorities concerned, including the location where the Data Subject resides, is substantially affected or where a complaint has been lodged.
Links to Other Websites
This Privacy Notice does not cover the links within this site linking to other websites which are not controlled by us. We are not responsible for the collection or use of your personal information from these third-party websites.
Therefore, we encourage you to read the privacy statements on the other websites you visit.
Changes to How We Protect Your Privacy
Our Digital Services are continually under review – new functions and features are periodically added and improved to interface, thus changes to our Privacy Notice may be required from time to time.
We therefore encourage you to check our Privacy Notice on a frequent basis.
How to Contact Us
We are always happy to hear from you, whether to make a suggestion but especially if you feel we can do better.
If you have any questions about this Privacy Notice, or if you wish to make a complaint about how we have handled your personal information, please contact us at:
EPG Financial Services Limited
Level 4, The Plaza Commercial Centre, Bisazza Street, Sliema SLM 1604, Malta