Privacy & Cookie Policy

DATA CONTROLLER:
‍PayProff A/S
CVR-nummer: 40914307
Ouskær 32,
7100, Vejle,
Denmark
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Contact information for Data Protection Officer:
Constantin Jørgensen: support@payproff.com


‍Data protection and data security are of paramount importance at PayProff. We process and use personal data only to the extent necessary in order to provide our services.

We ask you to carefully read our Terms & Conditions and Privacy Policy which together form part of our agreement with you.


1. Introduction
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1.1. When creating a user profile(“Profile”), you are entering into a legal agreement with us about the use of our services on the PayProff platform.

1.2. To administrate your profile while offering our services in compliance with the agreement, we need to process your personal data. We process your personal data pursuant to the GDPR, article 6(1, para b) to fulfil an agreement with you as registered.

1.3. This Privacy Policy accounts for how we treat and store your data.

2. Member Discretion

2.1 It is our wish to safeguard the personal data of all our users best possible.Therefore, we have a member discretion policy, which implies that you cannot use or share information about other users obtained through PayProff or given to you by PayProff or by other users. Information obtained through PayProff can only be used for purposes of entering into or completing trades.

3. Categories of personal information

We only gather the necessary personal information about you, and therefore we have listed and described the different categories of information below, which we process.

We process the following personal information about you:

3.1 User information:
   • First name
    • Surname
    • E-mail address
    • Residence
    • Nationality
    • Date of birth
    • Address
    • Postal code
    • Phone number
   • KYC documentation (e.g. photo ID like passport) and KYC behavioural questions about the purpose and intended nature of the business relationship.

3.2 Technical Data; IP address and connection information

3.3 Transactions information:
  • IBAN and/or bank Reg. No. and Account No.
   • Payment card information
   • Transaction data (amount, currency, transaction parties, dates etc.)

3.4 We do not process any special categories of personal information about you(art.9), such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sexual orientation or sex life.

You should avoid providing us with any further special categories of personal information, when reaching out to us.

4. Registration of your Profile Information

4.1. Our support department can rightfully contact you at any time to ensure that you meet our age criteria of 18 years of age to utilize the platform. If you are contacted, you may be asked to provide relevant identification documents. The information you share in relation to this is only used to green light you as a user and is not used or stored for other purposes.

4.2 Verification of your identity

4.2.1. In order to maintain and strengthen the security and trust of our platform, we need to verify your identity in various contexts. Among other things, it prevents fraud and unauthorized use of our service e.g., other persons use other people’s PayProff profiles, or when the user has not reached the required age of 18 years.

4.2.2. The specific purposes and basis for treatments constitute:
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Routine control of the required age limit of 18years. Our basis for the process is Article 6 (1)(f) of the GDPR about legitimate interests. Our legitimate interest in checking your age is the natural interest in protecting ourselves and our users on the platform from entering into invalid agreements. The use of PayProff’s service when you use our service as a payment service and are obliged to verify the seller on the basis of the requirements for customer knowledge procedures followed in chapter3 of the Money Laundering act (Hvidvaskloven). Our basis for the processArticle 6 (1)(c) of the GDPR about treatments which are necessary to comply with legal requirements.
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4.2.3 We use Criipto ApS as a verification service for natural persons in Denmark. To read more about Criipto’s data policy click here. We use Penneo A/S as a verification service and to store KYC information for legal entities inDenmark. To read more about Penneo’s Data Processing Agreement click here.

5. Data processing in PayProff

5.1 Hosting

PayProff is using Microsoft Ireland Operations Ltd. as its hosting and cloud infrastructure provider.
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5.2 Creating a PayProff account

In order to create a PayProff account, you must sign up by providing your email address, phone number and you must choose a password. As soon as you confirm your email address by clicking the link in your inbox, you need to verify your identity with NemID. After you have successfully logged in with your personal NemID, you need to provide us with the details mentioned in Art. 3.1 and Art. 3.3.

5.3 PayProff services
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PayProff offers a service that allows you to transfer and/or receive money to and from other PayProff users as part of a deal you have entered into outside of the PayProff platform. Our basis for processing your personal information (see 3), as either a buyer or seller, using our services, is Article 6(1)(f) of the GDPR about legitimate interest.Our legitimate interest is in providing you the service you are requesting PayProff.

5.3.1 In order to deliver the service, we process your user information. For safety reasons, we also collect the IP addresses of both the seller and the buyer when processing monetary transactions. We ask you to be aware that parts (Name,Surname and email) of your profile information (see 3.1) are shared with the buyers and/or sellers that you trade with. Other information is not available to be accessed by others other than PayProff
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5.3.2 As a seller
In order for us to facilitate a trade/ deal between you and the buyer, we are processing your personal information in order to provide the service. When receiving payments in connection to the trade/ deal, you will be required to inform us of your account- and registration number or IBAN of your bank account. Due to anti-money laundry regulation, it is only allowed to receive payments on your own account.

5.3.3 As a buyer
When you choose to buy enter a trade/ deal, there are currently three types of payment methods: by card (we ask you for your cardholder data: card number, expiration date, and CVV number), byMobilePay (we ask for your phone number), and by bank transfer (we ask you to use a unique reference number when you execute the transfer). When you make a payment by card or MobilePay, the amount can be withdrawn directly from your card. To safely process the transactions, we use a secure third-party service, called Penso Pay A/S. To read more about Penso Pay’s privacy policy click here.

5.4 PayProff support and service
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5.4.1 In connection to your continuous use of our service, we process all data related to your profile as necessary to provide and improve our service. In order for us to provide you with the best possible support and continuously improve our services, it is necessary for us to process the following categories of user information; technical information and transaction information (see 3), and any other information you may provide us when requiring our support. Our basis for processing your information is our legitimate interest providing you with great service and support (GDPR par. 6(1)(f)).

5.4.2 We offer you our support services from our support team, should you have any questions or problems on our service. In relation to cases in our support department, we process all information given to us by you as well as your user information and your profile data, should it be of relevance.

5.4.3 Information processed in or given by our support department is safely stored in the PayProff platform.

5.4.4 All information related to a transaction, deemed relevant to the danish acts on bookkeeping, anti-money laundry and payments will be stored for 5 years to comply with regulatory requirements.

5.5 Marketing on Social Media and Newsletters

5.5.1 We use your user information (see 3) to target our content and advertising to your interests. This happens on our own platform as well as on social media, so you can receive relevant marketing material. We process your information based on your consent to do so (GDPR Article6(1)(a). We process your information in pursuant to our legitimate interest in marketing our services (GDPR par. 6(1)(f)).

5.5.2 By accepting our terms and conditions, you consent to PayProff using your email address to send you newsletters and other direct marketing material.

5.5.3 You are free to withdraw and adjust your marketing consent at any given time by sending us an email to support@payproff.com.

5.6 Statistics

All data listed above is used by us in anonymized or randomized forms for statistical purposes in order to improve our service. Our basis for this is the GDPR, article 6 (1), (f) on our legitimate interest, which does not in principle exceed the consideration of your personal rights.

6. Data Sharing (Third parties)

We share data with third parties, only if necessary to provide our service. Third parties should be understood as the following:
   •  Authorities or others in relation to legal demands and obligations, or for the protection of our legitimate interests in a legal conflict.
   •  Third party to facilitate the transactions: Banking Circle S.A., PensoPay A/S (user information, transaction information)
    • Third party to facilitate the identity verification: Criipto ApS and Penneo A/S (user information)
    • Support administrator: n/a
    • Business intelligence: Google Analytics (technical information)
    •  Secure services within data processing that assist us or the PayProff corporation with IT or other services

7. Data security

7.1 To protect your data against accidental or illegal destruction, loss, changes, unauthorized access, or transfer in compliance with the data protection regulations in Denmark and in the EU, we store all personal data with our secure data processing partners.
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7.2 Our data processing partners are located within the EU or in the US with companies that have joined the US Privacy Shield agreement. Partners may also be located in third countries with companies that process data in compliance with the standard contractual clauses of the European Commission. PayProff APIs and services all run onHTTPS that uses Transport Layer Security (or TLS) by default. This means that all communications are encrypted.

7.3 All our employees are bound by confidentiality agreements, are going through a due diligence process, and we have restricted the access to personal data to what is strictly necessary.
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8. Closure of Your Profile

8.1 You can ask us to close down your profile at any time. To do so, you can contact us by email at support@PayProff.com.

8.2 Regardless of all information given prior, your profile will not be closed until all ongoing transactions and support cases are finished.

8.3 All information related to a transaction, deemed relevant to the danish acts on bookkeeping, anti-money laundry and payments will be stored for 5 years, as we are obligated to comply with these laws (See section 5.3.4)

9. Your rights

9.1 You can request to receive an exported file of the personal data we hold about you, including any data you have provided to us (data portability). You can also request that we rectify or erase any personal data we hold about you. Pleases end your request to support@PayProff.com.
    • The right to withdraw consent
    • The right of access
    • The right to erasure
    • The right to rectification
    • The right to data portability
    • The right to object
    • Notification of data breaches
    • The right to lodge a complaint with a supervisory authority

9.2 You can always access your information on your profile and edit your information if your address or email has changed. Asa user of the platform, you are responsible for having correct and updated information on your profile. To update your information, go to Profile.

9.3 You are welcome to contact us for additional information about our processing and storage of your data. You are also welcomed to contact us to update, edit, delete or request information that you cannot administer yourself on your profile.

9.4 We kindly inform you that you cannot exercise your rights in cases where the rightful interests of PayProff or other parties in favour of the continued processing of your information exceed your interests in the protection of your personal data. For instance, we claim the right to collect debts, negative interest rates for holding funds for an excessive period of time, money laundering suspicions or investigate fraud.

9.5 If you wish to make a complaint about our treatment of your data, we ask you to contact us directly without any hesitation. If we are not in a position to help you, you can direct your complaint to the Danish Data Protection Agency.

10. Cookies
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This website does not use cookies.
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‍11. Changes to the Privacy Policy
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We maintain our right to make changes to thePrivacy Policy at any time. If the changes made to the Privacy Policy are substantial, we will inform you in an email or directly on the PayProff service.

This Privacy Policy was last updated 10.10.2022.