LynkPay PRIVACY NOTICE
Welcome to the Lynkpay Ltd Privacy Policy 2022.
- GENERAL
Lynkpay Ltd respects this notice and is committed to protecting your personal data. This privacy notice will inform you of how we look after your personal data when you visit our website (regardless of where you visit it from), engage with us in any other way, how we process our clients’ personal data when we provide our services and tell you about your privacy rights.
This notice describes how Drivers Pay Ltd, the company who operates LynkPay, and its affiliates collect and use personal data. This notice applies to all users of LynkPay website, app, features, or other services. This notice specifically applies to:
- Riders: individuals who request or receive transportation, including those who receive transportation requested by another individual
- Taxi Drivers: individuals who provide, or submit applications to Drivers to provide, transportation individually or through partner transportation companies
This website and our services are not intended for children and we do not knowingly collect data relating to children.
- WHO ARE WE?
We are DriversPay (company name Drivers Pay Limited and herein referred to as “DriversPay”, “LynkPay website”, “we”, “us” or “our” in this privacy notice). DriversPay is the controller of your personal data and responsible for LynkPay website, our office is located at Unit 9, Mendip Business Park, Mendip Road, Rooksbridge, Axbridge, BS26 2UG.
- CONTACT DETAILS
We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
If you have any questions about this privacy notice o
r our privacy practices, please contact us in the following ways:
- Sending us an e-mail to dataprotection@lynkpay.com
- Using our website contact form.
You have the right to make a complaint at any time to the Information Commisioner’s Office, the supervisory authority for data protection issues in the United Kingdom (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the Information Commisioner’s Office.
- WHAT IS PERSONAL DATA?
Personal data is any information that relates to a living individual who can be identified from that information either by the information alone or together with any other information likely to come into (or already in) our possession. It does not include anonymous information. The obtaining, storing and use of personal data is governed by the General Data Protection Regulation 2016/679 and UK Data Protection Act 2018.
If your place of resident is other than the EEA, please contact us for further information.
- DATA WE COLLECT ABOUT YOU
Personal data refers to any information that tells us something about you or that we can link to you. LynkPay processes any information we receive from you, including personal and financial information you provide to us including when you or your business: make a payment, enquire or make an application for Allied Wallet’s services, register to use and/or use any of our services and when you communicate with us through e-mail, SMS, WhatsApp, a website or portal, telephone or any other electronic means.
Such information may include you or your customer’s: • name including first name and family name, date of birth, e-mail address, billing address, username, password and/or photograph, address, nationality and country of residence; • card account number, card expiry date, CVC details, bank and/or issuer details; and/or • information relating to any items purchased, including the location of the purchase, the value, the time and any feedback that is given in relation to such purchase.
By processing, we mean everything we can do with this data such as collecting, recording, storing, adjusting, organising, using, disclosing, transferring or deleting. For more information about the way we use your personal data, please refer to Section 9 (“What we do with your personal data”).
You share personal information with us, for example when you: visit our website, complete a(n) (online) (application) form, sign a contract, make a payment or alternatively use our payment services, or contact us through one of our channels.
We also use data that is legally available from public sources such as commercial registers, debtor registers and the media, or data that is legitimately provided by other companies within Drivers Pay Ltd or by third parties.
We 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 considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). However, for compliance checks we do collect information about criminal convictions and offences.
- IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, you may not be able to use our services and we will notify you if this is the case at the time.
- CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get 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 notify you and we will explain the legal basis which 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, where this is required or permitted by law.
- AUTOMATED DECISION-MAKING
We use technologies that are considered automated decision making or profiling. We will not make any automated decisions about you that would significantly affect you unless such a decision is necessary for entering into, or the performance of, a contract with you, we have obtained your consent, or we are required by applicable law to use such technology. You will find information on your right to object to this processing of your data below under Rights as a data subject.
- SECURITY OF PERSONAL INFORMATION
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we 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 in place procedures 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 store all the personal information you provide on our secure (password- and firewall-protected) servers.
And we have implemented physical access restrictions for our data centres and authorization controls for data access as part of our information security management system.
All electronic financial transactions entered into through our website will be protected by encryption technology.
You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
- HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial, Profile, Transaction, Technical, Usage and Compliance data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes (but is not limited to) personal data you provide when you:
- Apply for our services;
- Create an account on our website;
- Use our services;
- Communicate with us;
- Interact with us for the purpose of collaborating with us;
- Make payments in relation to our services;
- Subscribe to our publications;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey; or
- Give us feedback.
Automated technologies or interactions. As you interact with our website or any device application through which you may access our services, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie notice for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including, but not limited to:
- Companies that introduce you to us;
- Delivery and postal services;
- Card associations;
- Government and law enforcement agencies;
- Agents working on our behalf including fraud prevention agencies, analytics providers, advertisers;
- Companies providing due diligence and other screening activities;
- Media outlets (including social media outlets); and
- Business registration websites.
All our website financial transactions are handled through the following payment services: (i) credit card or debit card processed through our Internet merchant account; and (ii) payment providers; and (iii) any other payment methods as defined in the relevant page of the Website. We will share information with our payment services providers only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
- WHAT WE DO WITH YOUR PERSONAL DATA
We only use your personal data for legitimate business reasons. This includes:
- When you open a merchant account we are legally obliged to collect personal data that verifies your identity (such as a copy of your ID card or passport) and to assess whether we can accept you or your company as a customer. We also need to know your address or phone number to contact you.
- Managing customer relationships. We may ask you for feedback about our products and services and share this with certain members of our staff to improve our offering. We might also use notes from conversations we have with you online, by telephone or in person to customise products and services for you.
- Credit risk. To assess the financial position of your company we apply specific risk models that may involve the use of personal data.
- Personalised marketing. We may send you letters, emails, or text messages offering you a product or service based on your personal circumstances, or show you such an offer when you log in to our website or mobile apps. You may unsubscribe from such personalised offers. You have the right, not to consent or to object to personalised direct marketing or commercial activities, including profiling related to these activities.
- Providing you with the best-suited products and services. When you visit our website, call our customer service centre or visit a branch, we gather information about you. We analyse this information to identify your potential needs and assess the suitability of products or services. For example, we may suggest investment opportunities suited to your profile. We analyse your payment behaviour, such as large amounts entering or leaving your account. We assess your needs in relation to key moments when a specific financial product or service may be relevant for you, such as starting your first job or buying a home. We assess your interests based on simulations you participate in on our website.
- Improving and developing products and services: Analysing how you use our products and services helps us understand more about you and shows us where we can improve. For instance, when you open a merchant account, we measure the time it takes until your first transaction to understand how quickly you are able to use your merchant account.
- We analyse data on transactions between you and our corporate customers (merchants) to offer information services. When Allied Wallet processes personal data for this purpose, aggregated data may be made available to the Allied Wallet merchant (webshop/onlineFF retailer). This merchant cannot identify you from these aggregated data.
- We analyse the results of our marketing activities to measure their effectiveness and the relevance of our campaigns.
- Preventing and detecting fraud and data security: We have a duty to protect your personal data and to prevent, detect and contain data breaches. This includes information we are obliged to collect about you, for example to comply with regulations against money laundering, terrorism financing and tax fraud. We may process your personal information to protect you and your assets from fraudulent activities, for example if you are the victim of identity theft, if your personal data was disclosed, or if you are hacked.
- We may use certain information about you for profiling (e.g. name, account number, age, nationality, IP address, etc.) to quickly and efficiently detect a particular crime and the person behind it.
- Our merchants (webshops/online retailers) may use contact and security data to secure transactions and communications made via remote channels.
- Internal and external reporting: We process your data for our payment operations and to help our management make better decisions about our operations and services. To comply with a range of legal obligations and statutory requirements (anti-money laundering legislation and tax legislation, for example).
Data that we process for any other reason is anonymised or we remove as much of the personal information as possible
- DISCLOSING PERSONAL INFORMATION
We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this notice.
We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this notice.
Access to your personal data is limited to employees, agents, contractors and purchasers (or prospective purchasers) of DriversPay who need access to it in order to provide you with our services; to communicate with you (including, with your consent, to send you marketing communications); and to carry out legal or regulatory obligations.
We may also employ the services of third-party service providers to help us in certain areas, such as website hosting, physical security, marketing and market research. Where third party service providers receive your information we will remain responsible for the use of your personal data. We take appropriate steps to ensure that such third parties treat your Personal Information with the same consideration that we do.
We may from time to time be required to disclose your personal data to law enforcement bodies, regulators, tax agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this website privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.
- INTERNATIONAL DATA TRANSFERS
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this notice.
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the UK and the EEA.
Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
By providing us with your personal data, you expressly consent to our transferring your personal data to countries or jurisdictions which may not provide the same level of data protection as your home country, including without limitation countries or jurisdictions outside the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
- RETAINING PERSONAL INFORMATION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of 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 we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We maintain a retention procedure which we apply to records in our care. In all cases, where your information is no longer required we will ensure it is disposed of in a secure manner and, where required by applicable law, we will notify you when such information has been disposed of.
In some circumstances we will 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.
- CHANGES TO THE WEBSITE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy notice under regular review and may make updates and changes from time to time.
You should check this page occasionally to ensure you are happy with any changes to this notice.
We may notify you of changes to this notice by email or through the private messaging system on our website.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- MARKETING
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile 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 products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or services from us and you have opted in to receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by sending us an email to dataprotection@lynkpay.com or by following the unsubscribe function present in each and every marketing communication sent to you.
- THIRD-PARTY LINKS
This privacy notice applies only to services and information collected by LynkPay website, app and interactions with the company, be it only or offline; however, our website may contain links to third-party websites, plug-ins and applications.
Please be aware that clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Notice. (add hyperlink)
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read attentively the list below to find out more about these rights:
Your right | What does it mean? | Limitations and conditions of your right |
Right of access | Subject to certain conditions, you are entitled to have access to your personal data (this is more commonly known as submitting a “data subject access request”). | If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations. |
Right to data portability | Subject to certain conditions, you are entitled to receive the personal data which you have provided to us and which is processed by us by automated means, in a structured, commonly-used machine readable format. | If you exercise this right, you should specify the type of information you would like to receive (and where we should send it) where possible to ensure that our disclosure is meeting your expectations. |
Rights in relation to inaccurate personal or incomplete data | You may challenge the accuracy or completeness of your personal data and have it corrected or completed, as applicable. We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details, telephone number. | This right only applies to your own personal data. When exercising this right, please be as specific as possible. |
Right to object to or restrict our data processing | Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data. | As stated above, this right applies where our processing of your personal data is necessary for our legitimate interests. You can also object to our processing of your personal data for direct marketing purposes. |
Right to erasure | Subject to certain conditions, you are entitled to have your personal data erased (also known as the “right to be forgotten”), eg where your personal data is no longer needed for the purposes it was collected for, or where the relevant processing is unlawful. | We may not be in a position to erase your personal data, if for example, A) we need it to comply with a legal obligation, or B) exercise or defend legal claims. |
Right to withdrawal of consent | As stated above, where our processing of your personal data is based on your consent you have the right to withdraw your consent at any time. | If you withdraw your consent, this will only take effect for future processing. |
If you wish to exercise any of the rights set out above, please contact us at dataprotection@lynkpay.com
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
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.
This privacy notice was last updated on 19th September 2022