Satispay Europe S.A. (“we” or “Satispay”) is the data controller of your personal data and, according to Regulation EU 2016/679 on the protection of natural persons with regard to the processing of personal data (the “Regulation”), wishes to inform you about the way your information is processed.
Moreover, Satispay is an electronic money institution providing e-money and payment services authorized to conduct its business in several EU countries (“EMI Services”).
Satispay has also appointed a data protection officer. As for the requests concerning your use of the Forum, you can contact the data protection officer at the email address firstname.lastname@example.org.
What information do we process?
Examples of information we collect and process are the following:
- the information required to register on the Forum (name, surname, e-mail address);
- the content you post on the Forum and any other information you share through the Forum or relevant contact channels;
- data gathered in relation to your use of the Forum (including registered activities, IP address and information collected through other technologies that do not reveal your specific identity).
What do we use your information for?
We process your personal data for the following purposes and in accordance with the below legal basis:
- to provide our community service requested by you (which allows discussions and sharing of knowledge in relation to a wide range of topics, including on Satispay, the industry in which it operates and relevant services) and manage your Forum account. Your personal data is processed also to introduce to you and provide information on our EMI Services and other products and services offered by Satispay group companies. These data processing activities are carried out in order to take steps at you request prior to entering into a contract and/or on the basis of the contractual relationship with you following your registration on the Forum;
- to improve your experience in using our EMI Services and other products and services offered by Satispay group companies and to carry out statistical and trends analysis — your information and feedback are useful to improve the services offered and develop additional products and services. This processing is carried out on the basis of our legitimate interest to enhance the quality of the products and services of Satispay and the Satispay group companies;
- to communicate with you and provide you with additional customer service channels — your information helps us to more effectively respond to your requests and support needs regarding our and other Satispay group companies’ products and services. This processing is carried out on the basis of the contractual relationship with you following your registration on the Forum and/or a request of assistance within the existing contractual relationship with Satispay for its services. Additionally, this processing is also carried out on the basis of our legitimate interest to provide you with the most efficient service possible;
- to analyse and improve your experience on the Forum — your information helps to improve the Forum offerings based on feedback we receive from you. This processing is carried out on the basis of our legitimate interest to enhance the quality of your experience in using the Forum;
- to communicate with you about the Forum by email - the email address you provide may be used to send you information and notifications that you request about changes to topics or in response to your user name, respond to inquiries, and/or other requests or questions. You can always unsubscribe from receiving these if you want to and manage your preferences in your account settings. This processing is carried out following your permission.
The personal data collected may also be processed in the context of any corporate events (sale of the company or going concerns), due diligence exercises, in the event of defence of legal claims and related prodromal activities. This processing is carried out on the basis of our legitimate interests in the continuation of Satispay’s commercial activities and the protection of Satispay’s rights.
Finally, we might process your personal data for compliance with any legal obligation including any possible request from the competent authorities.
How do we protect your information?
Satispay has set up specific data security measures and procedures in order to ensure the safety of your personal data and to prevent accidental loss or misuse.
How long do we keep your information?
We hold your information for only as long as necessary for the purpose for which they are processed, in accordance with applicable laws. Your data will be stored, in compliance with the applicable law, for a term not exceeding what is necessary to pursue the purposes for which they were processed.
The criteria for determining the storage period of the data take into account the allowed processing period and the applicable law on limitation of your rights and legitimate interests, where these are the legal basis for processing.
As long as you are registered to the Forum or until you exercise your erasure right your data will be retained, without prejudice to any need of retention arising from any legal basis applicable to us.
Personal data may be stored for a longer period after having been aggregated and/or anonymised in such a way that the identification of individuals is no longer possible.
Whom may personal data be shared with?
We do not sell, trade, or otherwise transfer for marketing purposes your personal data to third parties. We share your data with our staff, Satispay group companies and other trusted third parties, including our Forum provider, where necessary, in order to keep the Forum working, for example, through outsourcing of the provision and management of the Forum, as long as those parties agree to keep this data confidential. The information and content you share on the Forum might be anonymized or aggregated in order to be transferred to Satispay group companies to develop and improve new products and services.
We may also disclose your information when required to comply with the law, enforce our Forum terms, or protect ours or others rights, property, or safety. Public posts on the Forum will be publicly available. Your contents posted herein will be visible also to visitors without a Forum account and might be reproduced or shared by other people.
Your personal data may also be transferred to companies located outside the EEA. In this case, Satispay will ensure the protection of the data by stipulating, if necessary, agreements that guarantee an adequate level of protection and/or adopting the standard contractual clauses provided by the European Commission.
Yes, we use technical cookies (which do not require user’s consent). Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow). These cookies are necessary to provide the basic functionality of the Forum, including to recognize your browser and, if you have a registered account, associate it with your registered account.
All the most recent browsers allow the user to change the settings of cookies. These are usually in the menu of the user’s browser under “options” or “preferences”. To understand how to set them up, you can follow the instructions concerning your browser following the relevant link (Mozilla Firefox; Internet Explorer; Microsoft Edge; Google Chrome; Safari; Safari on iPhone, iPad o iPod touch; Opera).
Exercise of your personal data rights
In accordance with the Regulation, you have the following rights:
- obtain confirmation as to whether or not your personal data are being processed, and, should this be the case, access your personal data processed by us and obtain a copy of it;
- rectification of your personal data if incorrect and/or incomplete;
- erasure of your personal data and restriction of processing in the cases provided by the Regulation;
- restriction of the processing where one of the grounds provided for by art. 18 of the Regulation applies;
- receipt of your personal data provided by you, in a structured, commonly used and machine-readable format and transmission of those data to another controller from Satispay;
- objection to legitimate interest, direct marketing, automated decision-making processing.
You can withdraw the consent to the processing of your data (if this was given) at any time, without prejudice to the lawfulness of the processing based on consent before its withdrawal.
You can exercise your rights by contacting us at the e-mail address email@example.com or use the dedicated channels available on the Forum.
If you believe that we are in breach of the Regulation, please do not hesitate to contact us telling us what you consider to be the case, so that we can resolve the problem as soon as possible. In any event, without prejudice to any other administrative or judicial appeal, you may also file a claim with the competent Supervisory Authority (Commission nationale pour la protection des données) if you consider that the processing concerning you is done in violation of the Regulation. Further information is available on the website National Data Protection Commission - Luxembourg.
Third party links
Occasionally, you might find on the Forum links to other content such as websites, web apps and downloadable apps, provided by us or by third parties using the Forum. These third party contents have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these third party contents.