Judopay's Privacy Policy

Effective Date: 20/01/22

1. INTRODUCTION

Alternative Payments Ltd (also known and trading as Judopay) is registered in the United Kingdom under Company Number 07959933, with its registered address at Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP (“Judopay”, “we”, “us”, “our”).

Alternative Payments Ltd is registered with the UK Information Commissioner’s Office (ICO) under number ZA080409.

Judopay respects your privacy and is committed to protecting your personal data. This privacy policy(“Privacy Policy”) will inform you about how we use and look after your personal data when you visit our website or when we provide our services to you. We will tell you about your privacy rights and how the law protects you.

2. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Judopay collects and processes your personal data through all your engagements with us, when using our services, including use of this website (www.judopay.com), including any data you may provide when you sign up to our services or request information about other services from Judopay.

This website and our services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Judopay as Data Processor

If you are a customer of one of our partners, this Privacy Policy does not apply in respect of your financial and/or payment services account data you provide to our clients, as we are not the data controller of such data.

In these circumstances, Judopay is acting as a data processor and our partners remain the data controller in respect of such personal data. To the extent that we are acting as a data processor, we will process such personal data in accordance with our partners’ documented instructions and any agreements in place with our partners.

Our partners are responsible for ensuring that their customers’ privacy is respected, including communicating to customers in their own privacy policies who their personal data is being shared with and processed by. You should review the Privacy Policy of our relevant client for more information on what personal data they will collect from you and what will be shared with us as a data processor for our clients.

Judopay as a Data Controller

Judopay may also act as a Data controller and make decisions about processing activities. In such cases Judopay has overall control of the personal data being processed and are ultimately in charge of and responsible for the processing.

3. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. anonymous data.

For clients and users of our products and services, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
Contact Data includes billing address, correspondence address, email address and telephone numbers.
Financial Data includes bank account details, credit reference data, financial accounts and reporting, business plan, plus historic payments volume and values.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us. Includes details of card and other electronic payments details, transaction data – purchases and refunds, end-customer disputes leading to chargebacks, and other payment related data as permitted by the payment networks and our third-party relationships.
Technical Data includes internet protocol (IP) address, your login data, browser type, language and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and our services.
Social Media Data includes Facebook, Twitter, Instagram, LinkedIn, etc.
Usage Data includes information about how you navigate and use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Hiring Data includes work history usually in the form of a CV, identity, contact details, education qualifications and employment references.

We do not collect any Special Categories of Personal Data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

For prospective employees and contractors of Judopay, we may collect, use, store and transfer different kinds of personal data about you when you apply for a job at Judopay. This includes information within your CV or resume and any additional information we may request over the phone or via email to support our processing of your job application. Please see our Privacy Policy to Job Applicants.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Apply for our services.
Apply for a job with us.
Enter into an agreement with us.
Subscribe to our service or publications.
Give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your computing equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Analytics providers such as Google based outside the EU.
Social media networks
Identity and Contact Data from publicly availably sources such as credit bureaux based inside the EU, former employers, references, etc.

5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data for the purposes we communicate to you and when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform specific actions in support of the contract we are about to enter, or have entered into with our clients, partners and third parties.
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.
Where we need to comply with a legal or regulatory obligation.
To inform you of relevant activities and services from Judopay and our key partners.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at: Privacy@judopayments.com.

Judopay has appointed a Data Privacy Manager who is responsible for overseeing activities, any questions in relation to this Privacy Policy and responding to specific queries about the processing of data held by us.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (including an opt-out mentioned in this Privacy Policy), please contact the Data Privacy Manager using the details set out below:

Data Privacy Manager

Alternative Payments Limited

Address: Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP

Email: Privacy@judopayments.com

Tel: +44 (0) 203 503 0600

www.judopay.com

You have the right to make a complaint at any time to the competent supervisory authority for data protection issues. In the UK, this is the Information Commissioner’s Office (ICO). Contact details can be found at www.ico.org.

At Judopay we would, however, appreciate the chance to understand and address your concerns before you approach the competent supervisory authority so please contact our Data Privacy Manager in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We reserve the right to update this Privacy Policy at any time, and, where appropriate, we will notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

This version was last updated on the effective date at the top of this Privacy Policy, being 20 January 2022 and previous versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not own or control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you on our key contacts database.	(a) Identity (b) Contact (c) Experience (d) Preferences, interests and hobbies, i.e. for employees	Legitimate Interest – providing a service to new and existing clients as well as employees and job candidates. Please visit our Privacy Notice for Job Applicants.
To process your agreement including:(a) Manage terms, payments, fees and charges (b) Collect and recover monies owed to Judopay / Alternative Payments	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Other for use by our merchant acquirers	(a) Performance of a contract with you (b) Necessary for our legitimate interests to keep our records updated (and pay monies owing or recover debts due to us).
To manage our relationship with you, which will include: (a) Notifying you about changes to our terms or this Privacy Policy. (b) Informing you of relevant product and service updates. (c) Informing you of relevant new product and service offerings.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests – providing products and services(c) Necessary for our legitimate interests to keep our records updated as to areas of interest and to study how interested parties use our services.
To deliver relevant website content and potential available services to you and measure or understand the effectiveness of the details we share with you.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests to study how visitors come to and travel through our website, use of our products and services, to develop our products and services, to grow our business and to inform our marketing and communication strategy.
To use data analytics to improve our website, services, marketing, client / potential client relationships and experiences.	(a) Technical (b) Usage	Necessary for our legitimate interests to define types of interested parties for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
To make suggestions and recommendations to you about events, research opportunities, case studies and updates that may be of interest to you.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests to develop our services and grow our business.
To process electronic payment credentials and end-customer authentication on behalf of Judopay clients	(a) Identity (b) Technical (c) Usage (e) Profile	Necessary for our legitimate interests to provide our payment processing services to clients and their customers, on behalf of the merchant acquirer and in accordance with payment scheme rules and applicable payments and security regulations. Necessary in support of the obligations on Judopay to prevent, detect and manage payment fraud.

Third-party marketing

We do not sell your personal details to third party partners for marketing purposes.

Opting out

You can ask us to stop sending you marketing communications emails at any time by following the opt-out links on any marketing or communication message sent to you or by contacting us at any time, see below:

Data Privacy Manager

Alternative Payments Limited

Address: Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP

Email: Privacy@judopayments.com

Tel: +44 (0) 203 503 0600

www.judopay.com

Where you opt-out of receiving these messages, this will not apply to personal data provided to us as a result of any contractual or legal relationship or obligations we have with you.

Cookies

We employ cookie technology to help log visitors to our web site. Cookies are pieces of data that are often created when you visit a website, and which are stored in the cookie directory of your computer or mobile device. A number of cookies may be created when you visit the Judopay website. The cookies do not contain any personal information about you, and they cannot be used to identify an individual user.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some of the enhanced features of this website may become inaccessible or not function properly. Please see our Cookie Policy below.

View Cookie Policy here.

‍Log files‍

When you visit this website, we collect web statistics concerning your visit, which are stored in a log file. Log files allow us to record visitors’ use of the site. Log files are also used to detect potential harmful users, which may be reported by us to the relevant authorities.

6. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with relevant third parties for the operation of your contract with Alternative Payments Limited.

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law(s) and our own strict requirements. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will not sell, rent, lease or otherwise share your personal data other than as outlined in this Privacy Policy or without obtaining your consent beforehand. We will share your personal data with our staff and other members of our corporate group as necessary to carry out the purposes for which the information was supplied or collected.

Personal data may also be shared with our third party service providers, data processors and affiliates who assist with the running of this website and our Services including:

G-Suite;
Google Cloud;
Google Analytic;
LinkedIn; and
Slack;

Our third party service providers and data processors are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.

Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf. Such activity may result in the compliant processing of personal information. Our appointed data processors include: (i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro is registered with the ICO Reg: ZA346877. Their Data Protection Officer can be emailed at: dpo@sopro.io.

In addition, Judopay may disclose personal data about you to our professional advisers including lawyers, auditors and insurers.

7. INTERNATIONAL TRANSFERS

Judopay, may transfer your personal data outside the European Economic Area (EEA). Personal data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer personal data that we obtain about you to recipients in countries other than the country in which the personal data was originally collected, including to the United States.

In such cases we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal data remains protected to the standards described in this Privacy Policy.

This means that Judopay will take all reasonable legal, technical, and organisational measures to protect the data. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Where we use providers based in the US, we may transfer data to them if they are part of the UK IDTA which requires them to provide similar protection to personal data shared between Europe and the US. Where we use service providers based outside the EEA, we may use standard contract clauses approved by the European Commission which give personal data the same protection it has in Europe.

8. DATA SECURITY

We treat the privacy and security of the personal data we hold very seriously.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, transferred, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to the same duty of confidentiality.

We have put in place procedures to deal with any suspected or confirmed personal data breach and will notify you on the details held for you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, 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 you can ask us to delete your data (please see the legal rights section below for further information).

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this aggregated information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

As a Data Subject, you have the right to:

Request access to your personal data (commonly known as a"data subject access request"). This enables you to receive a copy, in an agreed machine-readable format, of the personal data we hold about you and to check that it is complete, current and we are lawfully processing it. In certain situations, we may seek further clarification of your data access request, e.g. where the request is complex or sizeable.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Also known as the right to rectification.
Request erasure of your personal data. Also commonly known as the “right to be forgotten”. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data's accuracy;
where our use of the data has not been lawful, but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you advise us of your request to withdraw your consent.

If you wish to exercise any of the rights set out below, please contact us at:

Data Privacy Manager

Alternative Payments Limited

Address: Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP

Email: Privacy@judopayments.com

Tel: +44 (0)203 503 0600

www.judopay.com

No fee is usually required. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we reserve the right to charge a reasonable fee if we believe that your request is clearly repetitive or excessive.

Where we believe that a request is excessive, e.g. significant amounts of data are requested, we will attempt to clarify in more detail exactly what you are looking for. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We endeavour to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. In such cases we will respond within two months of the date we clarified your request or the fee to access the data was paid.

Your right to complain

We would, however, appreciate the chance to understand and address your concerns before you approach the competent supervisory authority. So please contact our Data Privacy Manager in the first instance:

Data Privacy Manager

Alternative Payments Limited

Address: Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP

Email: Privacy@judopayments.com

Tel: +44 (0)203 503 0600

www.judopay.com

Changes to our Privacy Policy

Any changes we may make to the Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check this page frequently to see any updates or changes to this Privacy Policy.