privacy policy

1. Scope

As a customizable Payment Orchestration Platform, our primary goal is to streamline and enhance your payment processes. We serve as a centralized hub for managing multiple payment providers, enabling seamless API integrations, optimizing transaction routing, and offering advanced reconciliation and reporting tools.

By utilizing state-of-the-art technology, we ensure a seamless and secure payment ecosystem for merchants and payment service providers worldwide.

This Privacy Policy (“Policy”) describes how and why we collect, process, and utilize any information that you share with us when using the website. We will always correctly and intentionally process the data you provide us with in accordance with current legislation, with a focus on your rights as a customer.

We are committed to protecting your privacy and safeguarding your data. Any information by which you can be identified while using the Website (“Personal Information”) will only be used in accordance with this Policy.

By using our Website, you confirm your consent with the Privacy Policy. If you do not agree with the terms of this Privacy Policy and do not wish to provide us with the personal information we require, please do not use this Website.

If you have any questions regarding this data policy or your rights as a data subject, please contact us via email.

2. Definitions

All references to “User”, “customer”, “end user”, “you”, “your” and/or “yours”, in this Privacy Policy, refer to any user who accesses and plays on our site.

Data Controller: A person, company, or other body that determines the purposes and means of the processing of personal data (this may be determined alone or jointly with another person/company/body).

Data Processor: A natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Controller.

Personal Data: Any information relating to an identified or identifiable natural person.

GDPR: The General Data Protection Regulation (2016/679).

3. Types of Data Processed by Our Company

We may ask you to provide some or all of the information mentioned below.

  • Information that you will be asked to provide to establish contact with us: company details (name, billing address); identity data of the beneficial owners, shareholders with 25% or more ownership of shares and directors; contact data (telephone number, email address).
  • Technical data, including but not limited to: IP address (the address used to connect your computer to the Internet) and device, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URLs), games played and the duration of each game and page, page interaction information ("Usage Data"); information received from cookies, including details of your visits to this site for an overview of traffic, games played, duration of each game and generally your behavior on the site. This information is collected in accordance with our Cookie Policy ("Cookie Data") and your preferences as expressed in the cookie banner on our site.
  • We will not collect or process any type of sensitive data, including but not limited to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, health data, data concerning an individual's sex life or sexual orientation.
  • Public source data which is publicly available information from third parties or publicly accessible sources, typically through Google searches, where this is necessary to comply with our legal obligations.

Merchant-Specific Data Processing

We process business data provided by merchants, including:

  • Merchant account details, such as company name, business registration, and tax identifiers.
  • Contact information for directors, shareholders, and employees, as necessary for compliance and account management.
  • Transactional data, including payment amounts, timestamps, and payment methods, to facilitate reporting, reconciliation, and fraud detection.

Types of Data Processed for Payment Orchestration

To facilitate efficient payment processing, we may collect and process the following data:

  • Transaction Data: Payment amounts, timestamps, currency, and transaction status.
  • Payment Method Information: Card details, bank account numbers, and e-wallet identifiers (where applicable).
  • Merchant Data: Account settings, user preferences, and integration configurations.
  • Analytical Data: Performance metrics for transaction routing and provider success rates.

This data is processed to fulfill contractual obligations, comply with legal requirements (e.g., AML/KYC), and optimize the efficiency of payment operations.

4. Disclosure of Data Subject Information

We may only disclose your personal data to the third parties listed below and for the following purposes:

  • Regulators and Authorities for legal obligations, regulatory reporting, and detection & prevention of fraud and crime.
  • Law Enforcement and Government for legal processes (e.g., court orders, subpoenas), fraud prevention & detection, and reporting criminal activities.
  • External Service Providers for provision of services (e.g., IP intelligence, email newsletters, payment processing) and supporting business operations. The list of external providers is as follows: (list of external service providers; if decided not to show, this can be removed).
  • Professional Advisors for legal rights and litigation purposes, risk management, and compliance with legal requirements.
  • Banks for resolving payment disputes and data verification.
  • Competent Authorities and Company Employees for customer support and service provision and performing assigned roles and tasks.

Data Handling During API Integration and Use of Third-Party Services

We utilize APIs and third-party services to enable seamless payment orchestration and streamline your payment processing needs. Through these integrations, we may process data such as transaction amounts, payment methods, and user credentials to facilitate connections between merchants and payment providers.

Third-Party Service Providers

We collaborate with trusted service providers for functions like fraud detection, reconciliation, accounting, and analytics. These providers operate under strict data protection agreements and comply with applicable laws to ensure the safety and confidentiality of your data.

When engaging with third-party services, we only share data essential to the service provision and ensure compliance with GDPR and other applicable data protection laws. Any third-party provider used undergoes thorough evaluation to meet industry standards and our internal compliance requirements.

5. Data Transfers

We will only transfer your data to the European Union or to countries deemed to provide an adequate level of protection for personal data by the European Commission. If subcontractors located outside EU countries are used, we will ensure that all data subcontractors used are audited and found to comply with European data protection standards.

We ensure that any cross-border data transfers comply with GDPR and other relevant regulations. Data is transferred to countries deemed to have adequate data protection laws by the European Commission, or through safeguards such as Standard Contractual Clauses (SCCs) and Binding Corporate Rules (BCRs).

For jurisdictions requiring data localization, we comply with local regulations to ensure data remains secure and legally handled.

6. Marketing

We will send you information about our services that may be of interest to you. If you have consented to receive marketing communications but change your mind and decide that you no longer wish to receive such information and withdraw your consent, you have the right to unsubscribe from such marketing communications at any time.

7. Security

Our website is committed to ensuring the security of your information. We have put in place measures and procedures to prevent unauthorised access to or disclosure of your information. Likewise, we endeavour to keep any information you send us confidential.

This site uses Secure Sockets Layer (SSL) technology to ensure the secure transmission of your personal data. You should see the padlock symbol in the status bar at the bottom right of the browser window. The URL will also start with https://, indicating a secure page. SSL applies encryption between two points such as your PC and the connecting server.

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 are subject to a duty of confidentiality.

We have put in place procedures to deal with any personal data breach and will notify you and the applicable regulator of a breach where we are legally required to do so.

8. Regulatory and Industry Compliance

Compliance with Payment Industry Standards

As a Payment Orchestration Platform, we are fully committed to adhering to industry standards and regulatory requirements, including:

  • PCI DSS Compliance: Our platform complies with the Payment Card Industry Data Security Standards to ensure the secure handling of payment card information during transactions. We employ encryption and tokenization technologies to protect sensitive data from unauthorized access.
  • Anti-Money Laundering (AML) Laws: We process personal and transaction data in compliance with applicable AML regulations, ensuring that we monitor, detect, and report suspicious activities in accordance with legal obligations.

Our compliance efforts are regularly audited to ensure we meet evolving security and regulatory requirements, maintaining the highest standards in the payment industry.

9. Data Retention

Our website is committed to the principles of purpose limitation, data minimization, and retention limitation as defined by the GDPR. Thus, all data will be retained for the duration of your relationship with us. We may retain your personal data where such retention is necessary to comply with a legal obligation to which we are subject, or in order to protect your legitimate interests or the vital interests of another natural person.

10. Rights of Data Subjects Under the GDPR

Our company will always take the GDPR into account when processing personal data, and it is therefore very important to us that you are familiar with your rights as a data subject.

  • Right to Transparent Information: We will always ensure that you are clearly informed about any personal data concerning you that may be processed by us. This information is provided to you in this Privacy Policy. For any additional questions, you can send an email to our data protection team, who will respond as soon as possible.
  • Right of Access to Information: You have the right to request confirmation from us as to whether personal data concerning you is being processed and, if so, to access that personal data.
  • Right to Submit a Request: You can always contact our Data Protection Officer (DPO) via email. If you wish to receive information about a specific data category, please indicate this category in your request.
  • Right to Rectification: You have the right to request the rectification, without delay, of any inaccurate personal data concerning you. You can submit a data amendment request by email to our designated address.
  • Right to Be Forgotten: You have the right to request the erasure of all personal data concerning you without delay, especially where the data has been processed based on your consent and/or where the processing is no longer lawful.
  • Right to Restrict Processing: You have the right to request a restriction of processing if:
    • The processing is unlawful;
    • You contest the accuracy of the data;
    • The data is no longer necessary for the controller, but you need it retained to establish, exercise, or defend a legal claim;
    • You have previously objected to processing.

    Once data is restricted, we may only process it to retain it unless:

    • We have your consent;
    • It is necessary to establish, exercise, or defend legal claims;
    • It is to protect the rights of others;
    • It is for reasons of important public interest.

    Please note this does not apply to personal data inferred or derived by us.

  • Right to Data Portability: You have the right to receive from us the personal data you provided and to transmit those data to another controller without hindrance. This right applies when the data is processed with your consent or for the performance of a contract and when the processing is carried out by automated means.
  • Right to Object: You have the right to object at any time to the processing of personal data concerning you where the processing is based on:
    • Our legitimate interests;
    • The performance of a task carried out in the public interest/exercise of official authority;
    • Direct marketing (including profiling);
    • Processing for scientific/historical research and statistical purposes.

    You also have the right to object to profiling based on our legitimate interests or the performance of a task in the public interest/exercise of official authority.

    Additionally, you have the right to object to automated decision-making, including profiling, and not to be subject to decisions based solely on automated processing that produces legal effects or similarly significantly affects you.

11. Requirements for Data Subjects

To protect the security of your account, we may need to request specific information from you upon receipt of a request in accordance with the above rights 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.

Our company is required to keep your data up to date and, for this reason, you may be asked at various intervals for information about changes to your personal data. You can help us with this process by informing us whenever your data has changed. You have the right to ask us to amend your personal data if you become aware that the personal data we hold is not accurate or up to date.

As we need your data to enter into and maintain a relationship with you and to fulfil our contractual and legal obligations, if you choose not to provide us with this data, we may not be able to establish a business relationship with you and comply with the Terms and Conditions applicable between us and our obligations arising therefrom.

Reference is made to the Terms and Conditions under which you have agreed to provide us with certain personal data and to inform us of any changes to that data. In these circumstances, the provision of personal data is a contractual requirement.

You are never obliged to provide us with data that we request on the basis of your consent, and your decision not to register or give us your consent will not affect your relationship with our company.

12. Privacy Policies of Linked Websites and Advertisers

Our website may contain, from time to time, references and links to third party websites and advertisers. We are not responsible for the privacy practices or the content of these websites. By clicking on these links, you may be directed to these websites which are not under our control and will be responsible for complying with the respective privacy policies of these third parties. If you have any questions about how these other websites use your information, you should review their policies and contact them directly.

13. Surveys and Contests

From time-to-time we collect information via surveys or for participation of any contests organized by us on the Site. Participation in these surveys and/or contests is completely voluntary, and any information provided to us will be provided based on your consent.

You may choose whether to participate and thereby disclose any information about you. There will be no detriment towards you for not participating in such surveys and contests. You may wish to revoke your consent at any time.

By agreeing to participate in the survey, you agree to provide us with any such required information. Survey information will be used only for purposes of improving the use and customer satisfaction of the Site.

14. Miscellaneous

Changes to Privacy Policy: This policy was updated on 19/12/2024.

We retain the right to change our Privacy Policy at any time in case update is needed. Any new changes shall apply from the date we publish them. Any further updates will be listed on this web page, so please check back periodically.

If you are unhappy with the way in which we have processed your personal data, or you have any additional questions, you may contact our Data Protection Officer/Data Protection Representative by sending an email to: email address.

You also have a right to lodge a complaint with the Office of the Information and Data Protection Commissioner, or other supervisory authority of your habitual residence, place of work or place of alleged infringement, and the right to seek an effective judicial remedy before courts.

COOKIE POLICY

Our website uses cookies to improve functionality and performance. This helps us provide you with a good experience when you browse our website and also allows us to improve our site.

What is a Cookie?

Cookies are small text files automatically placed on your computer, smartphone, or other device you use to visit a website or an application, which enable the website or the application to recognise visitors. The information stored in a cookie may relate to your browsing habits or may contain a unique identification number to allow the website to remember you on return visits.

Upon visiting our website, you will be presented with a cookie banner that allows you to accept or decline the use of non-essential cookies. You can modify your preferences at any time through the cookie settings panel available on our website.

This Cookie Policy complies with applicable data protection regulations, including the General Data Protection Regulation (GDPR) and ePrivacy Directive.

Purpose of Cookies

We use cookies on our platform for various purposes to enhance functionality and provide an optimized user experience. Some cookies are essential for the operation of our platform, enabling core features like logging in, navigation, and accessing secure areas. Others are used to remember your preferences, such as language settings or selected payment methods, to make your interactions more efficient.

We also use cookies to monitor platform performance and analyze user behavior. These cookies help us improve usability by tracking metrics like page visits and session durations. Additionally, marketing cookies may be used to deliver personalized content and advertisements tailored to your interests, as well as to measure the effectiveness of marketing campaigns.

Certain cookies are set by third-party service providers, such as analytics platforms or payment processors, to integrate external functionalities and ensure secure payment processing. By using our platform, you consent to the use of these cookies, which you can manage at any time through the cookie settings panel on our website.

How May Cookies Be Used?

Cookies can be helpful in a variety of ways such as allowing you to move between web pages efficiently, remembering your browsing preferences, measuring how you use the website so we can make sure it meets your needs, and in general improving your browsing experience. Cookies also help by ensuring that content and advertisements you see on a website are more relevant to your preferences.

The cookies that we use can be split into the following categories:

  • Strictly necessary cookies: these are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into parts of the website.
  • Analytical/performance cookies: these cookies allow us to recognise and count the number of website visitors and to see how they move around within the website when they are using it. This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies: these are used to recognise you when you return to the website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Third party cookies: these are set on your device by other websites whose services are used on our website. Cookies of this type are the sharing buttons that allow you to share content onto social networks. These cookies assist them in pinpointing the viewed pages, clicked links and ads and other actions you take on those webpages, and the site from which you came before arriving at their webpage.
  • Targeted Email Marketing: these cookies record your visit to the website, the pages you have visited and the links you have followed. We may share this information with third parties (see our Privacy Policy for more information on how we use information we collect from you). Some of the marketing may be tailored based on your past browsing, downloading and/or purchasing behavior with our Website. This information allows us to send you relevant marketing materials and avoid any content that might be of low interest to you.

If you wish to withdraw your consent to our use of cookies at any time, you will need to delete your cookies using your internet browser settings. In addition, your browser or device may offer settings that allow you to choose whether browser cookies are set. For more information about these controls, visit your browser or device's help material. Certain parts of the website may not work properly if you have disabled browser cookie use.