Privacy policy

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1- What data do we collect?

 

To provide its services, Paypuce needs to collect and process information about you. The data we collect depends on the context of your interactions with Paypuce and the choices you make, including the services provided to you.

Please note that you can choose which data you allow us to collect. When you are asked to provide personal data, you may refuse. If you choose not to provide the data necessary to provide the service, we may not be able to provide the service.
 

2- Categories of data processed

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The data we collect and process may include, but is not limited to, the following:

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• Identification data: we collect data about you such as your first and last name, e-mail address, postal address, telephone number and similar contact data, date and place of birth, gender, country and preferred language;

• Electronic identification data: we use cookies to collect data on how you use our website and consult our marketing e-mails. This may include, for example, information on which pages of the Paypuce website you have visited, how long you stayed or which items you clicked on;

• Professional details : nous recueillons des données vous concernant, telles que la fonction, l'intitulé du poste, le service, le nom de l'organisation, la taille et l'emplacement, et si vous agissez ou non pour le compte d'un client;

• Financial information: we collect your financial information, such as your financial account information, if necessary for accepting a payment or fulfilling contractual or related obligations;

• Contractual information: all information provided by the person concerned enabling Paypuce to fulfil its contractual obligations.

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In addition to the categories of data mentioned above, Paypuce warrants that, except to the limited extent that may be necessary in the course of employment and in the performance of a contract with a customer, we do not request or collect special categories of data (i.e. , personal information specifying criminal offences/convictions, medical or health conditions, biometric or genetic data, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying an individual's sex life).

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We also invite you to consult the HR section.

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3- How do we collect your data?

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This privacy notice applies to personal data, which is information that Paypuce collects from you and other third parties that specifically identifies you as an individual. Paypuce may collect your personal data in different ways.

 

We collect your personal data when you consent to the use of different categories of cookies by visiting our website. Cookies are small pieces of text that are downloaded to your computer or other Internet-enabled device when you visit a website. They allow Paypuce to collect information about the use of a website in order to improve the overall user experience.

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Cookies can be classified in two different ways, by ‘lifetime’ and by ‘domain’. There are two types of cookies classified by lifetime:

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• Session cookies, which are deleted once the browser is closed and are therefore not stored on the user's device.

• Persistent cookies, which remain stored on the user's terminal for a certain period of time. They are not automatically deleted. Your browser sends these cookies back to the website each time you visit it again, so that it can remember your preferences and personalise what you see on the screen.

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As far as the domain is concerned, a distinction is made between :

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• Proprietary cookies are cookies set by the website you are visiting. No other website can read them.

• Third-party cookies, which are set by websites when they use external services, which deposit their own cookies.

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4- Data collection method

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By visiting our website and accepting the use of certain categories of cookies, certain data may be transmitted to us (this data will depend on the categories of cookies that have been accepted). However, regardless of which cookies you have consented to use, all data transmitted is anonymised.

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Personal data we collect when you do business with Paypuce: We may collect and process your data when you do business with us. ‘Personal Data’ means information relating to an identified or identifiable natural person that Paypuce receives on behalf of the customer itself. Examples of categories of such personal data can be found in the previous section.

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Personal information we obtain from other sources: we may also periodically obtain personal and non-personal information about you from Paypuce's subsidiaries, affiliates, business partners or other third party sources where they are legally permitted to share such information with us, and add it to the information we already hold about you, such as, but not limited to:

 

• Updated business address information;

• Identification data;

• Financial information;

• Contractual information.

 

Personal data we collect when you apply online for a job: please refer to the HR section.

5- Purpose of collecting, using and processing personal data

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In order for the processing of personal data to comply with the General Data Protection Regulation (the ‘GDPR’), a legal basis must be identified prior to its implementation.

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We use or may use your personal data for the following purposes (or as otherwise described at the point of collection) in accordance with the lawful basis under the GDPR:

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• To provide you with the service you have requested;

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Processing is necessary for the performance of a contract with the data subject.

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• To provide you with information, access to resources or other services that you have requested from us on behalf of your organisation;

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Processing is necessary for the performance of a contract with the data subject.

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• To send you customer service (marketing) communications;

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Processing is necessary for the purposes of the legitimate interests pursued by the data controller.

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• To process communications you send to Paypuce and respond to your questions, requests and complaints;

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Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract;

 

Processing is necessary to comply with a legal obligation.

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• To fulfil our legal obligations, in particular with regard to AML/KYC/ MAR ;

 

Processing is necessary to comply with a legal obligation.

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• To carry out the recruitment process;

 

Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract.

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• To promote our events and conferences via photos and videos posted on our social networks;

 

Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.

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• To manage Paypuce's infrastructure and business operations and to comply with internal policies and procedures;

 

Processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party.

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• To comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist law enforcement and investigations by the relevant authorities.

 

Processing is necessary to comply with a legal obligation.

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We may contact you by mail, telephone, fax, video conference, e-mail or other electronic messaging service to inform you of special events, new features or other information that may be of interest to you in connection with your interaction with Paypuce. Where required by applicable law, your prior consent will be obtained before we send you direct marketing and you may object or refuse to receive marketing messages from Paypuce. 

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Paypuce does not sell, rent or lease your information to third parties under any circumstances.
 

6- Sharing your personal data

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Paypuce shares your personal data if necessary to provide any service you have requested or authorised. 

 

Paypuce may also share your personal data with your consent for the following purposes:

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• Recruitment ;

• AML/KYC (third parties such as notaries, direct debit agents and banks, acquirers).

 

7- Disclosure of your personal data

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• Service Providers: We may disclose/transfer your data to third parties whom we refer as service providers only to the extent necessary to enable those service providers to provide services to Paypuce and to assist us in providing services to you. It is Paypuce's policy to maintain contracts with all third parties with whom we disclose/transfer personal information that restrict their access, use and disclosure of personal data. Service providers must, in fact, comply with our confidentiality and data security requirements and are not permitted to use the personal data they receive from us for any other purpose.

• Third parties: we may disclose/transfer your data to third parties such as government and public authorities, banking institutions, notaries, direct debit agents and Paypuce's professional advisers and auditors.

• Affiliates/Branches/Subsidiaries: We may disclose/transfer your data, as provided in our terms and conditions, to other companies jointly owned or controlled with Paypuce who will treat your information in accordance with this Privacy Policy.
• Safety, security and legal compliance: We will access, transfer, disclose and retain personal data to comply with applicable law or respond to subpoenas, court orders or other valid legal process, for national security reasons, to defend against legal claims, to protect the rights and safety of Paypuce, Paypuce's customers, employees or others. This may involve sharing your data with law enforcement agencies, government agencies, courts and other organisations. 
• Consent: We may share your data in other ways and for new purposes if you have asked us to and have consented to such sharing.

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Recipients may be located inside or outside the European Union. Your personal data will not be transferred to any country outside the European Union which does not offer an equivalent level of protection, unless :

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• You have given us prior authorisation to do so;

• If specific measures, such as standard contractual clauses (SCC), have been signed, or if the companies concerned have adopted binding corporate rules, guaranteeing that the provisions of the applicable law on data protection have been complied with.

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Where personal data is transferred/disclosed to Paypuce affiliates/branches/subsidiaries, this transfer is based on specific measures, in particular the standard clauses issued by the European Commission regarding the transfer of personal data outside the European Union. 

If you wish to consult the latter, please inform us by contacting us using the contact details provided in the ‘HOW TO CONTACT US’ section of this policy.

 

8- Access to personal data
 

Paypuce ensures that you can exercise your rights at any time. Paypuce will process any request within the limits of its technical and organisational resources.

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These include:

 

Right of access to your personal information: if you wish to see the data we hold, collect and process about you, please let us know by contacting us using the details provided in the ‘HOW TO CONTACT US’ section of this policy.

 

Right of rectification: if the data we hold, collect and process about you is inaccurate or incomplete, you have the right to update this data at any time by contacting us using the contact details provided in the ‘HOW TO CONTACT US’ section of this policy.

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Right to erasure: If at any time you decide that you do not want us to retain the personal data that we have collected from you, you may request that we delete your data by contacting us using the contact details provided in the ‘HOW TO CONTACT US’ section of this policy. We will take reasonable steps to comply with your request in accordance with applicable law.

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Right to restrict processing: if you wish to exercise this right, please contact us using the contact details provided in the ‘HOW TO CONTACT US’ section of this policy. You should only be granted the right to restrict processing if this is in accordance with applicable law.

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Right to object: if you wish to exercise this right, please contact us using the contact details provided in the ‘HOW TO CONTACT US’ section of this policy. We will consider your objection and comply with it unless we have a compelling legitimate reason as permitted by applicable law.

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Right to data portability: you may have the right to have your personal data transferred directly from us to another data controller only where you have asked us to do so and have consented to such sharing, and where it is technically possible. If you wish to exercise this right, please contact us using the details provided in the ‘HOW TO CONTACT US’ section of this policy.

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Right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (the ‘CNPD’), if you believe that your data is being processed in a way that does not comply with the GDPR.

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Please note that these rights are not always absolute and there may be situations where, technically or legally, Paypuce may not be able to respond to your request.

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9- How do we protect your data?

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Paypuce recognizes your trust and is committed to protecting the data you provide us.

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Paypuce pays particular attention to the ethics of working from home. We don't take hard copies home and require our employees to carry out any tasks requiring the use of hard copies from the office. 

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We maintain appropriate organisational, physical and technical security measures (including personnel, facilities, hardware and software, storage and networks, access controls, monitoring and logging, vulnerability and breach detection, incident response, encryption of personal data) to protect against unauthorised or accidental access, loss, alteration, disclosure or destruction of personal data.

 

10- Personal data breach notification

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Paypuce will inform its customer of any violation of personal data by Paypuce, its subcontractors or any other third party acting on behalf of Paypuce as soon as possible, only when the violation of personal data is likely to result in a high risk to the customer's rights and freedoms.

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11- Retention period for personal data

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Paypuce will only keep your personal data :

 

• For as long as is necessary for the purpose or purposes for which it was intended;

• For the purposes of performing or fulfilling a contractual obligation with you or the organisation you represent and therefore for legitimate business purposes;

• As long as required or permitted by law.

 

12- What we expect from you 

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We expect you to inform us in writing as soon as possible of any changes to the information you have provided, so that we can keep it up to date.

 

If you provide us with personal information which does not relate to you (for example, information about your respective representatives, members of staff and agents, beneficial owners, shareholders, etc. or any third parties), you must first inform them and ensure that they acknowledge that we may use that information as set out in this Privacy Policy. In particular, you must provide them with information about their rights as data subjects. We assume that such third parties are aware of the processing of any personal information about them that we may carry out and of the disclosure of such information to third parties and countries as described herein and that, to the extent necessary, you have obtained such data subjects' prior written consent.

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13- Modification of this personal data policy

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We reserve the right to change this Privacy Policy from time to time to reflect changes in the law, our data collection and practices, and to ensure that it is accurate, complete and up-to-date*. You are advised to check this Privacy Policy from time to time.

 

*Last updated on 07/2023

 

14- How to contact us

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If you have any questions or concerns about our use of your information or about our privacy policy, you can contact us by sending an e-mail to info@paypuce.com. 
 

15- Human resources and job applications

Personal information we collect when you apply online for a job: You may submit personal information through the use of our website to be considered for employment with Paypuce. This information includes, but is not limited to, your name, address, telephone number, e-mail address, experience, education, job skills and other information contained in your curriculum vitae (CV) and/or cover letter. Paypuce uses this data solely for the purposes of considering your application for employment, communicating with you and generating related correspondence, including offer letters and employment contracts. This data may also be used, subject to applicable local laws, to conduct background checks necessary for compliance and other employment-related purposes (including evaluating your profile for a potential employment contract, to the extent permitted by applicable laws and regulations). Finally, Paypuce retains this data only for as long as is necessary to process your application for employment and any questions that may arise regarding the processing of your application.

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