INTRODUCTION
At Verofy® we respect your privacy and are committed to protecting your personal data. This privacy policy, together with the terms of any contract we enter into with you, explains how we will collect and process your personal data when you use our website, and when you apply for, access and use our services, or you provide goods and services to us (including about you if you are a director or owner or authorised user or signatory of a company who applies for and uses our services or who supplies goods/services to us). It also tells you about your privacy rights, and how data protection law protects you. We carry out regular reviews of our privacy policy. This version was last updated on 1 February 2024.
Please read this policy so you understand how and why we will use your personal information. Use the links below to click through to specific areas of the policy. We might provide additional data processing notices as we collect or process your personal information. They will apply in addition to this policy.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your information changes during your relationship with us.
If you are providing personal information to us about other individuals, you must explain to them, before you provide their information to us, what categories of personal data you are sharing and how we will use their personal information (as explained in this Privacy Policy).
JUMP TO SECTION
1. ABOUT US
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. HOW WE WILL SHARE YOUR PERSONAL DATA
6. COOKIES
7. CARDHOLDERS
8. DATA SECURITY AND RETENTION
1. ABOUT US
This privacy policy is issued on behalf of the following companies in the Verofy® group:
When this privacy policy refers to “we” or “us” or “our” it means the particular Verofy® company above who operates the website/application or enters into a contract with you or provides the services that you are giving your personal information in relation to. That company will be data ‘controller’ responsible for the processing of your personal data.
If you are a cardholder who has bought goods or services as a customer of a merchant who receives payment processing services from a Verofy® company, we will process information about you so that we can process your debit/credit card payments. Click here for further information.
If you have any questions about this privacy policy, including any request to exercise your legal rights, you can contact us at dpo@verofy.com or write to us at our registered office address at Bank House, Bank Street, Whitefield, Manchester M45 7JF.
2. THE DATA WE COLLECT
Personal data or personal information means information about an individual that can be used to identify them. We may collect and process different kinds of personal data about you:
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not treated as personal data because this data will not directly or indirectly reveal your identity.
If we need to collect personal data by law, or under the terms of our contract, and you do not provide that data when asked, we may be unable to perform the contract or provide our services to you. We will tell you at the time if this ever happens.
3. HOW WE COLLECT YOUR PERSONAL DATA
Most of the personal information we process about you is given to us by you directly when you:
We also receive personal information about you from the following sources.
Credit Reference and Fraud Prevention. When considering your application for our services and managing your contract with us, and as part of our supplier due diligence checks on providers of goods/services to us, we may make searches at credit reference agencies (CRAs) (including Experian) about you, and in the case of a company, the owners, directors, and authorised users and signatories, including for the purpose of verifying your identify.
The CRA may check the details they supply against information held about you on any database (public or otherwise) to which they have access, including electoral register information in order to verify your identity and will keep a record of the search (a ‘footprint’ on your file) which may be used by others to make decisions about you and your financial associates. We may share information, including about how you conduct your agreement, with CRAs. If false or inaccurate information is provided and/or fraud is identified, details will be passed to fraud prevention agencies to prevent fraud and money laundering.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data where we have a lawful basis. We may have more than one lawful basis, depending on the purpose it is being used. The lawful bases we rely on are either:
The following table describes the purposes that we use your personal data and the legal basis we will rely on.
| Purpose | Lawful basis for processing |
| Register you as an applicant or customer, and assess your application for our services (including to help us assess our financial and insurance risks) | To enter into or perform a contract with you Necessary for our legitimate interests (for running our business, to prevent fraud) |
| To register you as a provider of goods/services to us, to carry out supplier due diligence checks and to manage our relationship with you (including to help us assess our financial and insurance risks) | To enter into or perform a contract with you Necessary for our legitimate interests (for running our business, to prevent fraud) |
| Provide our services to you and manage your access to them, and keep records relating to your transactions and use of our services | To enter into or perform a contract with you Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) To comply with a legal obligation |
| For managing the security, and to prevent misuse, of our websites, applications and services | To enter into or perform a contract with you To comply with a legal obligation Necessary for our legitimate interests (for running our business, to prevent fraud) |
| Manage our relationship and communicate with you, including to tell you about changes to our terms or privacy policy, or to ask you for feedback or to take a survey, and to manage any complaints, disputes or claims | To enter into or perform a contract with you To comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) |
| We may process your personal information to send you service communications including by email and SMS | To enter into or perform a contract with you |
| Collections and tracing, to manage payments, fees and charges and collect and recover money you owe us | To enter into or perform a contract with you Necessary for our legitimate interests (to recover debts due to us) |
| Conduct Know Your Customer (KYC), supplier due diligence, Anti Money Laundering, fraud prevention due diligence, identity and document verification, and other associated customer and supplier screening and to prevent and detect crime | To comply with a legal obligation Necessary for our legitimate interests (for running our business, to prevent fraud) |
| To provide updates about the status of your application and your use of our services to the third-party introducer/authorised seller who introduced your application to us as are necessary to verify the referral or other payments they receive in relation to your introduction to us. | Necessary for our legitimate interests (for running our business) To comply with a legal obligation |
| Administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, training, compliance procedures, reporting and hosting of data) | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) To comply with a legal obligation |
| To make suggestions and recommendations about products or services that may be of interest to you and to assess your eligibility for those products or services | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To send you marketing or other information that you have requested us to send, or any publications that you have subscribed to | Necessary for our legitimate interests (to develop our services and grow our business) Where you have given consent |
| Deliver relevant website/application content and advertisements to you, and measure or understand the effectiveness of the advertising we serve to you | Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
| Use of data analytics to develop and improve our website, services, marketing, and customer relationships and experiences | Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To process cardholder payments made using our services | To comply with a legal obligation Necessary for our legitimate interests (for running our business, to prevent fraud) |
Recording calls. We may monitor or record telephone calls or other forms of communication from you or your employees or agents to ensure instructions are carried out correctly and to monitor and help improve the quality of our services.
Automated decision making
We may sometimes use a scoring or other automated decision-making system when processing information, including personal data, about you provided by you or otherwise obtained (including information provided by third parties, about previous conduct/payment arrears, and from official public records). Where used, automated decision-making systems help us to make fair and reasonable decisions as to whether to provide services to an applicant, considering the financial security and status of the applicant. The methods and logic applied to any automated decision-making system will be tested and updated regularly to ensure they remain fair, effective and unbiased. Should the results of any scoring or other automated decision be too low, we are unlikely to conclude a contract with the applicant. Please write to us if you like to request that we reconsider a decision made solely by automated decision-making.
Marketing
We aim to give you choices regarding certain personal data uses, particularly around marketing and advertising. You can view and update your preferences via the applications you use to access our services.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us, or if you have requested or purchased services from us, and you have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages by contacting us at any time.
Change of purpose
We will only use your personal data for the purposes it was collected for unless we reasonably consider we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will tell you and explain the lawful basis that allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, if we are required or permitted to do so by law.
We may share your personal information with:
We require all third parties who process your information on our behalf to respect the security of your personal data and to treat it in accordance with data protection laws. 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.
Our websites and applications use cookies to distinguish you from other users. A cookie is a small file of letters and numbers that may be placed on your browser or the hard drive of your computer or device when you visit and/or use certain features of our website or access our services. They help us to facilitate and improve your experience of our website and applications and to provide and improve our services. We do not share the information collected by cookies with any third parties.
Types of cookies and what they do:
Strictly necessary cookies. These are cookies that are essential for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of our services. Your consent will not be sought to place these cookies, but it is still important that you are aware of them. You can still block these cookies by changing your internet browser settings (as explained below), but please be aware that our website and applications may not work properly if you do so.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website and applications when they are using them. This helps us to improve the way they work, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise the content for you, greet you by name and remember your preferences.
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed and they are used to make our website/applications more relevant to your interests.
We use the following cookies:
| Cookie Title Cookie Name | Purpose | Strictly Necessary |
| _ authUser | This cookie enables you to log into secure areas of the website. | Y |
| enums | This cookie enables us to improve the performance of the website by keeping the global options loaded. | Y |
| currentCustomerId | This cookie is used to recognize your last selected customer so we can pre-select him again. | Y |
| Functionality cookies | ||
| deviceUniqueId | This cookie is used to recognize your device when you return to our website. This enables us to track your login and decide which security level is needed | N |
Before any Analytical, Functionality or Targeting cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those cookies. You may, if you wish, deny consent to the placing of cookies but note that certain features of our website and applications may not function fully or as intended.
Our website and applications may also use analytics services, which also use cookies. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, allowing us to better understand how our websites and applications are used so we can improve our websites and applications and the services offered through them. You do not have to allow us to use these Cookies, using them does enable us to continually improve our website and applications, making it a better and more useful experience for you.
In addition to the controls we provide, you can choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies, but this can be changed. Most internet browsers enable you to choose whether to disable all cookies or only third-party cookies. You can choose to delete cookies on your computer or device at any time, however you may lose information that enables you to access our website and applications more quickly and efficiently including, but not limited to, login and personalisation settings.
7. CARDHOLDERS WHO PURCHASE GOODS/SERVICES FROM MERCHANTS WHO USE VEROFY® SERVICES
| The data we collect: | Cardholder personal data provided in connection with a payment transaction, which may include: Card Information such as card number, expiry date, card scheme/issuer, and Transaction Information such as usage, currency, issuer country, merchant id, transaction date, transaction amount). |
| How we collect your personal data: | We collect your information when you make a payment through a Verofy® card terminal or online using services provided by Verofy® to the merchant seller. |
| How we use your personal data: | We will process your personal data for the purpose of processing the payment transaction you requested in relation to your purchase with the Verofy® merchant, and to prevent fraud |
| How we will share your personal data: | We may share your information with financial institutions such as card schemes and the card issuer, fraud prevention services, other third parties and companies within our group who provide services to us in connection with the services we provide to merchants |
7. INTERNATIONAL TRANSFERS
We may sometimes use third party data processors who are based outside the UK so their processing of your personal data will involve transferring your data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it in accordance with UK data protection laws which may include ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information about any international transfers and the mechanisms we use for any transfers of your personal data outside of the UK.
8. DATA SECURITY AND RETENTION
We have put appropriate security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also 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 a duty of confidentiality.
We have put procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will keep your personal data for as long as is reasonably necessary to fulfil the purposes it was collected for, including to satisfy any legal, regulatory, tax, accounting or reporting requirements. We may keep your personal data for a longer period in the event of a complaint, or if we reasonably believe there may be litigation in respect to our relationship with you.
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 it is processed and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see at “Your legal rights” below.
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 information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights include:
You are not required to pay any charges for exercising your rights. However, we may charge a reasonable fee, or refuse to comply, if your request is clearly unfounded, excessive, or repetitive.
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.
If you wish to make a request, you should contact us at dpo@verofy.com or write to us at Bank House, Bank Street, Whitefield, Manchester M45 7JF. We try to respond to all legitimate requests within one month. Occasionally it could 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.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at dpo@verofy.com or by writing to us at Bank House, Bank Street, Whitefield, Manchester M45 7JF. You can also complain to the ICO if you are unhappy with how we have used your data. You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Helpline number: 0303 123 1113. ICO website: https://www.ico.org.uk.