Effective Date: January 1, 2020
Please note: this Policy applies to Javelin Payments Ltd.
Jump to section:
Our Data Practices
- Information We Collect and Categories of Sources
- How We Use Your Information
- Our Lawful Bases for Processing (EEA and UK End Users Only)
- How We Share Your Information
- Our Retention Practices
Some Final Details…
- International Data Transfers
- Your Data Protection Rights
- Changes To This Policy
- Contacting Javelin Payments
About this Policy
Our goal with this Policy is to provide a simple and straightforward explanation of what information Javelin Payments collects from and about end users (“End User Information”), and how we use and share that information. We value transparency and want to provide you with a clear and concise description of how we treat your End User Information.
Please note that this Policy only covers the information that Javelin Payments collects, uses, and shares. This Policy also does not cover any websites, products, or services provided by others. We encourage you to review the privacy policies or notices of developers or those third parties for information about their practices.
Our Data Practices
Information We Collect and Categories of Sources
As explained in greater detail below, Javelin Payments has collected identifiers, commercial information, electronic network activity information, professional information, inferences, and other types of End User Information.
Information you provide. When you sign up for an account with Javelin Payments accounts, where applicable, we collect identifiers and login information required by the provider of your account, such as your username and password, or a security token. In some cases, we also collect your phone number, email address, security questions and answers, KYC (Know Your Customer) data and one-time password (OTP) to help verify your identity before connecting your account. When providing this information, you give the Javelin Payments the authority to act on your behalf to access and transmit your End User Information from the relevant Payments Service Provider. You may also provide us with identifiers and other information, including your name, email address, and phone number, when you contact us or enter any such information on our websites.
Information we collect:
- Account information, including financial institution name, account name, account type, account ownership, branch number, IBAN, BIC, and account and routing number;
- Identifiers and information about the account owner(s), including name, email address, phone number, date of birth, and address information;
We use your End User Information for a number of business and commercial purposes, including to operate, improve, and protect the services we provide, and to develop new services.
Our Lawful Bases for Processing (EEA and UK End Users Only)
For individuals in the European Economic Area (“EEA”) or the United Kingdom (“UK”), our legal basis for processing your End User Information will depend on the information concerned and the context in which we collected or processed it. Generally, however, we will normally only collect and process End User Information where:
- we need to fulfil our responsibilities and obligations in any contract or agreement with you (for example, to comply with our end user services agreements);
- to comply with our legal obligations under applicable law;
- the processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, to safeguard our services; to communicate with you; or to provide or update our services); and
- you have given your consent to do so.
To the extent we rely on consent to collect and process End User Information, you have the right to withdraw your consent at any time per the instructions provided in this Policy.
We retain End User Information for no longer than necessary to fulfil the purposes for which it was collected and used, as described in this Policy, unless a longer retention period is required or permitted under applicable law. As permitted under applicable law, even after you stop using an application or terminate your account with one or more developer, we may still retain your information (for example, if you still have an account with another developer). However, your information will only be processed as required by law or in accordance with this Policy.
Please refer to the “Your Data Protection Rights” section for options that may be available to you, including the right to request deletion of End User Information. You can also contact us about our data retention practices using the contact information below.
Your Data Protection Rights
Under applicable law, and subject to limitations and exceptions provided by law, if you are located in the EEA or UK, and in certain other jurisdictions, you may have certain rights in relation to the End User Information collected about you and how it is used, including the right to:
- Access End User Information collected about you;
- Request that we rectify or update your End User Information that is inaccurate or incomplete;
- Request, under certain circumstances, that we restrict the processing of or erase your End User Information;
- Object to our processing of your End User Information under certain conditions provided by law;
- Where processing of your End User Information is based on consent, withdraw that consent;
- Request that we provide End User Information collected about you in a structured, commonly used and machine-readable format so that you can transfer it to another company, where technically feasible; and
- File a complaint regarding our data protection practices with a supervisory authority (if you are in the EEA or UK, please refer to the following link for contact details: https://edpb.europa.eu/about-edpb/board/members_en).
Changes To This Policy
We may update or change this Policy from time to time. If we make any updates or changes, we will post the new policy on Javelin Payments website and update the effective date at the top of this Policy. We will also notify developers of any material changes in accordance with our developer agreements, as they are generally best positioned to notify their end users about such changes to this Policy, as appropriate.
Contacting Javelin Payments
If you have any questions or complaints about this Policy, or about our privacy practices generally, you can contact us at hello@javelinHQ.com or by mail at:
If you reside outside the EEA or UK:
Javelin Payments Ltd
15 Main Street