Privacy Policy

Version 1.1, last amended 21/06/2021

In this privacy policy we, Pay Shield Ltd, legal entity’s code 304923415, with our registered office at Westwood Business Centre Unit 5a (S a G), Westwood Industrial Estate, Off Continental Approach, Margate, Kent, England CT9 4JG (“LIVEKORTTI”), explain how we handle your personal data when you visit our website and use our services.

We will ask you to consent to our use of cookies in accordance with the terms of this notice when you first visit our website.

Our website incorporates privacy controls which provide you with controls on deciding how we will process your personal data. By using privacy controls, you can specify whether you would like to receive direct marketing communications.

In this notice you will find the answers to the following questions:

1. How we use your data?

2. When we provide your data to others?

3. How long we store your data?

4. What is our marketing policy?

5. What rights related to personal data you possess?

6. How we use cookies?

7. Other issues that you should take into account?

In case of any inquiries or if you would like to exercise any of your rights provided in this notice, you may submit such inquiries and requests by means provided in Contacts section.

You may contact us regarding all privacy related issues by email: [email protected].

All the terms used in LIVEKORTTI Terms and Conditions have the same meaning as in this Privacy Policy.

In the event Privacy Policy is translated into other languages and if there are differences between the English version and such translation, the English version shall prevail, unless otherwise provided.

1. How we use your personal data?

1. This Section provides the following information:

1. categories of personal data, that we process;

2. in case the personal data that we did not obtain directly from you, the source and specific categories of that data;

3. the purposes for which we may process your personal data; and

4. the legal bases of the processing.

2. We process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. We obtain such data through the use of cookies and similar technologies. We process such data to have a better understanding of how you use our website and services. The legal basis for this processing is our legitimate interest, namely monitoring and improving our website and services and accommodating the services for individual interests of every user.

3. We process your account data (“account data”). The account data may include your name and email address, phone number and other data that you provide while registering as well as your purchase history. We obtain such data directly from you. We process account data for the purposes of operating our website, providing our services, ensuring the security of our website and services and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract as well as our legitimate interest, namely monitoring and improving our website and services.

4. We process information relating to provision of services by us to you in our website (“transaction data”). The transaction data may include your contact details, bank account details and the transaction details. The transaction data is processed to supply purchases goods and provide services and keep proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

5. We process information related to anti-money laundering prevention measures (“AML data”). AML data may additionally include address or residence, ID documentation, including your photo, documents regarding your source of wealth, utility bill and others. We are required by the law to request such information to carry out “know your client” obligations.

6. We may process information that you provide to us for the purpose of subscribing to our email messages and newsletters (“messaging data”). The messaging data is processed to send you the relevant messages and newsletters. The legal basis for this processing is your consent. Also, if we have already sold goods or provided services for you in our website and you do not object, we may also process messaging data on the basis of our legitimate interest, namely seeking maintain and improve customer relations.

7. We may process information relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. In case of communication through our website, the website will generate the metadata associated with communications made using the website contact forms. The correspondence data is processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, ensuring uniform and high quality consultation practice and for investigating disputes between you and our employees.

8. We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

9. We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

10. In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
    
    

2. When we provide your data to others?

1. We may disclose your personal data to any member of our group of companies (including our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this notice. Such may include internal administration purposes as well as provision/sharing of IT services or data centres in the group.

2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3. We may disclose your personal data to our anti-fraud, risks and compliance providers insofar as reasonably necessary for the purposes of protecting your personal data and fulfilling our legal obligations.

4. We may disclose your personal data to our payment service providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, transferring funds and dealing with complaints and queries relating to such payments and transfers.

5. We may disclose your personal data to other service providers insofar as it is reasonably necessary to provide specific services (including, providers of servers and maintenance thereof, email service providers). We take all the necessary measures to ensure that such subcontractors would implement proper organizational and technical measures to ensure security and privacy of your personal data.

6. We may share hashed data with Google to allow measurement and reporting of online conversions driven by Google ad interactions. Google will keep your data confidential and secure using the same industry-leading standards they use to protect their own users’ data. For more information about Google enhanced conversion data, you can visit their ads policy here.

7. In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8. Persons, indicated in this Section may be established outside the United Kingdom, European Union and European Economic Area. In case we will transfer your personal data to such persons, we will take all the necessary and in the legal acts indicated measures to ensure that your privacy will remain properly secured, including where appropriate, signing standard contractual clauses for transfer of data. To find out more information regarding appropriate safeguards you may contact us via email: [email protected].
   
   

3. How long we store your data?

1. Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. In any case it shall be kept for no longer than:

1. account data will be retained for no longer than 5 (five) years following your last update on the account;

2. transaction data will be retained for no longer than 10 (ten) years following the end of provision of services;

3. AML data will be retained as long as it is necessary to comply with the related legal requirements;

4. messaging data will be retained for as long as your Account is active, unless you withdraw your consent earlier;

5. correspondence data will be retained for no longer than 6 (six) months following the end of such communication.

2. In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. I. e. usage data will be retained for as much as will be necessary for the relevant processing purposes.

3. Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
   
   

4. Marketing messages

1. In case you consent, we will send you marketing messages via email and/or leave a notification in an Account to inform you on what we are up to.

2. Also, if we already have provided services to you and you do not object we will inform you about our other products that might interest you including other information related to such.

3. You may opt-out of receiving marketing messages at any time.

4. You may do so by:

1. choosing the relevant link in any of our marketing messages;

2. contacting us via means provided in Contacts section.

5. Upon you having fulfilled any of the provided actions we will update your profile to ensure that you will not receive our marketing messages in the future.

6. Please be informed that as our business activities consists of a network of closely related services, it may take a few days until all the systems are updated, thus you may continue to receive marketing messages while we are still processing your request.

7. The opt-out of the marketing messages will not stop you from receiving messages directly related to the provision of services.
   
   

5. Your rights

1. In this Section, we have summarized the rights that you have under data protection laws. Some of the rights are complex thus we only provide the main aspects of such rights. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

2. Your other principal rights under data protection law are the following:

1. the right to access data;

2. the right to rectification (note that you may exercise most of this right by logging to your account here;

3. the right to erasure of your personal data;

4. the right to restrict processing of your personal data;

5. the right to object to processing of your personal data;

6. the right to data portability;

7. the right to complain to a supervisory authority; and

8. the right to withdraw consent.

3. The right to access data. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

4. The right to rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

5. In some circumstances you have the right to the erasure of your personal data. Those circumstances include when: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing and there are no other legal basis to process data; (iii) you object to the processing under certain rules of applicable data protection laws; (iv) the processing is for direct marketing purposes; or (v) the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. Such exclusions include when processing is necessary: (i) for exercising the right of freedom of expression and information; (ii) for compliance with our legal obligation; or (iii) for the establishment, exercise or defense of legal claims.

6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are when: (i) you contest the accuracy of the personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data, however we will only further process such data in any other way: (i) with your consent; (ii) for the establishment, exercise or defense of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.

7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

10. The right to data portability. To the extent that the legal basis for our processing of your personal data is:

1. consent; or

2. performance of a contract or steps to be taken at your request prior to entering into a contract, necessary to enter into such, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

13. In addition to specific measure provided in this Section or the website you may also exercise any of the rights indicated herein by contacting us via Contacts.
    
    

6. About cookies

1. Cookies are small textual files containing identifier that is sent by a web server to your web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

2. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
   
   

7. Cookies that we use
   

   In the website we use cookies of four main types, for the following purposes:

   1. Necessary Cookies – these cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work;

   2. Analytical Cookies – these cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site;

   3. Preference cookies – these cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred region.

   4. Marketing cookies – these cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

   
   
   

8. Cookies used by our service providers
   

1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

2. We made arrangements with other parties who place cookies through our platform. Nevertheless, we cannot fully control what they are doing with their cookies, so please see below a list of the cookies from other parties we use and their privacy statements.

3. This list is subject to change.

1. Google Analytics, AdWords and DoubleClick https://www.google.com/policies/privacy/

2. Facebook https://www.facebook.com/policies/cookies/

3. Retail Rocket – Real time adjusting the website to user needs http://rocketretail.com.au/privacy-policy/

4. Hotjar – User Research, Funnel Analysis, Screen Recordings https://www.hotjar.com/legal/policies/privacy

5. Chat - Fresh Desk https://www.freshworks.com/privacy/

6. Visual Web Optimizer (VMO) https://vwo.com/privacy-policy/

9. Enabling and Disabling Cookies and Disposal

   More information on enabling and disabling and deleting cookies can be found in the instructions and / or by using the Help function of your browser.

   You may disable the use of cookies, but some parts of our platform may not work properly thereafter.
   
   

10. Google Analytics, AdWords and DoubleClick
    Via our platform (s), cookies are placed from the US company Google, as part of the "Analytics", "AdWords" and "Double Click" services. We use these services to track and get reports about how visitors use the platform and how visitors interact with the ads displayed. Google may also transfer this information to third parties if Google is legally required, or if third parties process the information on Google's behalf. We do not have any influence on the use of the data by Google and / or third parties. We have allowed Google to use the data analytics information with other Google services. Read the privacy policy of Google (which can change frequently) to read what they do with your (personal) data they process via these cookies. The information that Google collects is anonymous as much as possible. The information is transmitted to and stored by Google on servers in the United States. Google claims to adhere to the Safe Harbor principles and is affiliated to the Safe Harbor program of the US Department of Commerce. This means that there is an adequate level of protection for the processing of any personal data.
    
    

11. Facebook, Twitter and Google+
    Our platform included buttons to promote web pages ("like") or parts ("tweeting") on social networks like Facebook, Twitter and Google +. These buttons work through snippets of code from Facebook, Twitter and Google+ itself originate. By means of this code are placed cookies. Please read the privacy statements of these companies (which may change regularly) to read what they do with your (personal) data they process via these cookies. The information they collect through these cookies is anonymous as much as possible. The information is transmitted to and through Twitter, Facebook and Google+ stored on servers in the United States. Twitter, Facebook and Google+ set to comply with the Safe Harbor principles and are affiliated with the Safe Harbor program US Department of Commerce. This means that there is an adequate level of protection for the processing of any personal data.
    
    

12. How can you manage cookies?

1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via information provided in the relevant browser website, for example Chrome; Firefox; Internet Explorer; Safari.

2. Blocking all cookies will have a negative impact upon the usability of many websites.

3. If you block cookies, you will not be able to use all the features on our website.

4. You can adjust your cookie preferences by clicking Cookie Preferences link in the footer of the page.
   
   

13. Third party websites

1. LIVEKORTTI privacy policy does not apply to third party websites that are connected by links to this platform. We cannot guarantee that these third parties are a reliable and safe use of your personal data. We encourage you to read the privacy statements of these websites before using such websites.

2. This list is subject to change.

1. Facebook https://www.facebook.com/privacy/explanation

2. Google https://www.google.com/policies/privacy/

3. Mailgun https://www.mailgun.com/privacy-policy

4. Cloudflare https://www.cloudflare.com/security-policy/

5. Mailcamp https://www.mailcamp.nl/privacy-policy/

6. Trustpilot https://legal.trustpilot.com/end-user-privacy-terms

7. CashShield http://www.cashshield.com/privacy/

8. Freshworks https://www.freshworks.com/privacy/

9. Retail Rocket https://retailrocket.net/privacy/

10. Visual Web Optimizer (VMO) https://vwo.com/privacy-policy/

11. PayPal https://www.paypal.com/us/webapps/mpp/ua/privacy-full

12. Trustly https://trustly.com/en/privacypolicy/

13. Paytrail https://www.paytrail.com/en/data-privacy-notice

14. BitPay https://bitpay.com/about/privacy
    
    
    

14. Children personal data

1. Our website and services are targeted at persons over the age of 16 or another age under respective country’s law which allow you to assume responsibility for obligations emerging from contractual relations and have a full capacity to take legal actions

2. If we have reason to believe that we hold personal data of a person under that age in our databases without having consent from the parent rights holder, we will delete that personal data.
   
   

15. Updating your data
    Please let us know if the personal information that we hold about you needs to be corrected or updated.
    
    

16. Changes to the notice
    Any changes to this notice will be published on the website and, in case of material changes, we may inform you about such via email.

Contact Details

Data Protection Officer’s e-mail address:

[email protected]