GoPay

Privacy policy

General

  1. This Privacy Policy governs the way we handle personal data and ensure its protection. We abide by Czech Act No. 101/2000 Coll., which makes provision with respect to personal data protection, as amended (hereinafter referred to as the “Act”).
  2. We undertake to protect information about our Clients and take care that their privacy is preserved.
  3. The operation of the GoPay Payment System is governed by the Privacy Policy together with the Terms and Conditions and other policies. This Privacy Policy governs under what conditions, how and in what scope we shall collect information about our Clients and how we shall handle it further, including information obtained through our website.
  4. Definitions used in this Privacy Policy have the meaning defined in the Terms nad Conditions unless expressly stated otherwise herein.
  5. In personal data processing we shall ensure that a Client’s rights are not infringed upon, in particular, the right to preservation of human dignity, and shall also ensure that the private and personal life of a Client is protected against unauthorised interference.
  6. A Client hereby grants us their consent to the processing of their personal data under these terms and conditions laid down in the Privacy Policy.
  7. If a Client requests information about the processing of their personal data, we are obliged to provide this information without undue delay. The information shall always contain a statement about the following: Information under this Subsection of the Privacy Policy is given hereinafter.
    1. The purpose of personal data processing;
    2. The personal data or categories of personal data that are the subject of processing including all information available on its source;
    3. The nature of automated processing in relation to its use for decision-making, if acts or decisions are taken on the basis of this processing the content of which is an interference with the Client’s rights and legitimate interests;
    4. The recipients or categories of recipients.
  8. A Client acknowledges that the provision of personal data is voluntary.
  9. We strive to maintain personal data protection to the highest degree and fulfil obligations pertaining to personal data handling. However, if a Client finds or presumes that we are carrying out processing of their personal data which is in contradiction with the protection of the Client’s private and personal life or in contradiction with the law, in particular if the personal data is inaccurate regarding the purpose of its processing, the Client may do the following:
    1. Ask us for explanation;
    2. Require that we remedy the arisen state of affairs. It can mean in particular blocking, correction, supplementing or liquidation of personal data.
  10. If a Client’s requirement pursuant to the previous Subsection of the Privacy Policy is found justified, we shall remove without delay the improper state of affairs.
  11. Other rights that a Client has in the processing of their personal data are stipulated by the provision of S. 21 of the Act.

    Information We Collect

  12. We usually collect, store and process the following information about our Clients obtained as part of use of the GoPay Payment System:
    1. Full name and surname including educational attainment;
    2. E-mail address;
    3. Mobile phone number;
    4. Residential address;
    5. Copies of any identification documents proving a Client’s identity, including a photograph and information stated in the above documents;
    6. Bank account number including a bank transaction statement and name of the account holder;
    7. Data about any transaction that has been made;
    8. Data about any credit, debit or any payment card including the PAN number, expiry date and name of the payment card holder;
    9. All communication that has taken place;
    10. Information obtained from questionnaires or similar forms that a Client may be asked to fill in;
    11. Information collected through cookies;
    12. Information about the operating system of a Client’s device and type of Internet browser;
    13. IP address and time when a Client’s device was connected;
    14. Data about a Client’s website visits, in particular operational data, localisation data, weblogs, etc., as well as data about a Client’s behaviour in the Internet environment.
  13. In the interest of fulfilling the statutory obligation to prevent fraud and the legalisation of proceeds from criminal activity, we may obtain certain information about Clients from third parties when a GoPay Account is opened and also whenever we consider it fit or necessary to prevent fraud and minimise financial risks; however, always on condition that information about Clients has been collected and preserved rightfully and in accordance with legal regulations and that it is at the same time admissible for us to obtain this information.
  14. In the interest of enhancing the quality of our services we store variable cookies in the device on which a Client accesses our website.
  15. We use different types of cookies for the following purposes:
    1. To identify a Client’s device;
    2. To enhance the security of the GoPay Payment System;
    3. To optimise our website;
    4. To provide or offer tailor-made services;
    5. For the services of third parties such as Google, Facebook and others that we use. For specific rules pertaining to the use of cookies please refer to the websites of third parties for information.
  16. By using the services of GOPAY’s website a Client acknowledges that we may use some or all types of cookies and agrees that we may store cookies in the device on which they access our website. If a Client disagrees with the above, they should stop using our website or adjust the settings of their Internet browser.
  17. If a Client wishes to continue using our services, yet wishes to limit the use of cookies, the Client may block cookies in their browser settings as the settings enable to refuse to accept all or some cookies. If a Client uses their Internet browser settings where all cookies are blocked, it is possible that the Client may not be entitled to access our website or parts thereof.
  18. GOPAY’s website may use certain types of cookies already when a Client visits it unless the Client’s Internet browser is not set up to block cookies.

    How we use information

  19. We use the information we preserve about Clients in the following way:
    1. To operate and administer a Client’s GoPay Account;
    2. To make or receive payments and internal messages in accordance with a Client’s instructions;
    3. To communicate with a Client;
    4. To fulfil statutory measures;
    5. To make internal analyses of the risk of a transaction including the obligation not to carry out a deal or block the making of payment transactions;
    6. To enhance the quality of, and secure, provided services;
    7. To ensure that the content of our website is presented on a Client’s device as efficiently as possible; and
    8. To provide information, products or services to Clients, which they demand from us or in which they may be interested.
  20. A Client also acknowledges and agrees that we may send them from time to time e-mails with information about the GoPay Payment System, newly provided services, innovations and recommendations or hints for using the GoPay Payment System and other services that we operate as well as trading hints and information about offers or services provided by our trading partners. A Client may adjust the settings in their GoPay Account if they are or are not interested in receiving such information or communications.

    What We Do for Security

  21. We have taken all measures necessary to ensure that personal data is handled in a secure manner and in accordance with the Privacy Policy regardless of where the data is preserved.
  22. We apply control system, anti-fraud management system and due diligence procedures so as to prevent unauthorised or accidental access to personal data, its alteration, destruction or loss, unauthorised transmission, other unauthorised processing, as well as other misuse of personal data; the measures are described in a documentation that was submitted to pertinent inspection authorities. This obligation shall remain valid even after terminating personal data processing.
  23. All Internet communication through our website is secured with the SSL technology with high-level encryption.
  24. A Client acknowledges that even with maximum possible caution, maximum effort to secure communication and preserving personal data in a secure manner, absolute information and data transmission security over the Internet cannot be guaranteed.
  25. Pursuant to Czech Act No. 253/2008 Coll. we are obliged to preserve certain records and data for a minimum period of five or ten years following the termination of a contractual relationship. We shall erase and destroy other personal data and information that we have collected about a Client as soon as a contractual relationship is terminated.

    Disclosure of Information

  26. A Client agrees that we may transfer or cede collected data to companies or other persons that are part of the same holding as our company and possibly also to companies where GOPAY’s associates or their related persons are in the position of associates, shareholders or members of corporate bodies.
  27. When Electronic Money is transferred to another GoPay Account holder we are entitled to transfer to the money recipient at least information about the e-mail address, residential address and/or mobile phone number of the money sender. Depending on the type of payment that is used we may receive a Client’s personal data such as name, surname, residential address, e-mail address, mobile phone number and country of residence from third parties, if the above information is necessary for improving the payment process or for carrying out our own due diligence against fraud or against the legalisation of proceeds from criminal activity. A Client agrees with the receipt of personal data within the meaning of the previous sentence.
  28. A Client agrees with the transfer of identification pursuant to S. 11(1, 2) of Czech Act No. 253/2008 Coll. provided the recipient of the identification protects personal data and information at least to the same extent that shall correspond to our standards. A Client also agrees that we receive their identification under terms and conditions that are otherwise governed by the provision of S. 11(1, 2) of Czech Act No. 253/2008 Coll.
  29. We are entitled to communicate personal data also to:
    1. A party interested in buying the enterprise of GOPAY or to a party interested in a major business share in GOPAY;
    2. Police authorities, investigating, prosecuting and adjudicating bodies, other authorised state authorities or public authorities and/or courts on condition that the obligation to communicate personal data follows from legislation or from a pertinent decision or if the communication of personal data shall be used to protect our rights, property or security or those of the holding of which we are part, of Clients or other contracting partners;
    3. Third parties, if a Client has shown interest in receiving information about their goods or services.
  30. We are entitled to provide summarised information about how Clients use our website and our services to third parties for statistical, research or analytical purposes; however, Clients may not be identified on the basis of this information.
  31. We are entitled to unilaterally amend the Privacy Policy in accordance with the rules and terms and conditions laid down in this Article. A Client agrees with the above entitlement.
  32. If we amend the Privacy Policy, we are obliged to notify the Client of this change in advance by e-mail containing a link to the new Privacy Policy from where a Client may print it or download it in electronic form.
  33. The Privacy Policy is issued in electronic form and is available at GOPAY’s website.
  34. The Privacy Policy comes into effect as of 10/1/2014.

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