Privacy policy in efect as of 2/11/2015

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 Account Terms of Use and other policies. This Privacy Policy governs under what conditions, how and in what scope we shall collect personal information about you 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 Account Terms of Use unless expressly stated otherwise.
5. In personal data processing we shall ensure that your rights are not infringed upon, in particular, the right to preservation of human dignity, and shall also ensure that your private and personal life protected against unauthorised interference.
6. You hereby grant us your consent to the processing of your personal data under these terms laid down in the Privacy Policy.
7. If you request information about the processing of your personal data, we are obliged to provide this information without undue delay. The information shall always contain a statement about the following:
   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 your rights and legitimate interests;
   4. The recipients or categories of recipients.
      
      Information under this Subsection of the Privacy Policy is given hereinafter.
8. You acknowledge 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 you find or presume that we are carrying out processing of your personal data which is in contradiction with the protection of your private and personal life or in contradiction with the law, in particular if the personal data is inaccurate regarding the purpose of its processing, you 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 your requirement pursuant to the previous Subsection of the Privacy Policy is found justified, we shall remove without delay the improper state of affairs.
11. Your other rights in the processing of your personal data are stipulated by the provision of S. 21 of the Act.

Information We Collect

1. We usually collect, store and process the following information 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 your 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 you may be asked to fill in;
   11. Information collected through cookies;
   12. Information about the operating system of your device and type of Internet browser;
   13. IP address and time when your device was connected;
   14. Data about your visits of our website, in particular operational data, localisation data, weblogs, etc., as well as data about your behaviour in the Internet environment.
2. 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 you 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 you 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.
3. In the interest of enhancing the quality of our services we store variable cookies in your device on which you access our website.
4. We use different types of cookies for the following purposes:
   1. To identify your 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.
5. By using our website, you acknowledge that we may use some or all types of cookies and accept that we may store cookies in your device on which you access our website. If you disagree with the above, do not access our website or adjust the settings of your Internet browser.
6. If you wish to continue using our services, yet wish to limit the use of cookies, you may block cookies in your browser settings as the settings enable to refuse to accept all or some cookies. If you use your Internet browser settings where all cookies are blocked, it is possible that you may not be entitled to access our website or parts thereof.
7. Our website may use certain types of cookies already when you visit it unless your Internet browser is set up to block cookies.

How We Use Information

1. We use the information we preserve about you in the following way:
   1. To operate and administer your GoPay Account;
   2. To make or receive payments and internal messages in accordance with your instructions;
   3. To communicate with you;
   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 your device as efficiently as possible; and
   8. To provide information, products or services to you, which you demand from us or in which you may be interested.
2. You also acknowledge and accept that we may send you from time to time e-mails with information about the GoPay Payment System, newly provided services, information about 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. You may adjust the settings in your GoPay Account if you are or are not interested in receiving such information or communications.

What We Do for Personal Data Security

1. 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.
2. 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.
3. All Internet communication through our website is secured with the TLS technology with high-level encryption.
4. You acknowledge 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.
5. 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 you as soon as a contractual relationship is terminated.

Disclosure of Information

1. You accept 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 the associates of our company or their related persons are in the position of associates, shareholders or members of corporate bodies.
2. 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 your 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. You accept the receipt of personal data within the meaning of the previous sentence.
3. You accept 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. You also accept that we receive your identification under terms that are otherwise governed by the provision of S. 11(1, 2) of Czech Act No. 253/2008 Coll.
4. We are entitled to communicate personal data also to:
   1. A party interested in buying the enterprise of our company or to a party interested in a major business share in our company;
   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, or you or other contracting partners;
   3. Third parties, if you have shown interest in receiving information about their goods or services.
5. We are entitled to provide summarised information about how you use our website and our services to third parties for statistical, research or analytical purposes; however, you may not be identified on the basis of this information.

Final Provisions

1. We are entitled to unilaterally amend the Privacy Policy in accordance with the rules and terms laid down in this Article. You accept the above entitlement.
2. If we amend the Privacy Policy, we are obliged to notify you of this change in advance by e-mail containing a link to the new Privacy Policy from where you may print it or download it in electronic form.
3. The Privacy Policy is issued in electronic form and is available on our website.
4. The Privacy Policy comes into effect as of 02/11/2015.