Introduction
DEK-CO (UK) LTD d/b/a PAYDEK ("Paydek") is authorized by the Financial Conduct Authority under the Payment Service Directive to provide payment services and is registered with the UK Data Protection Authority, the Information Commissioner"s Office (ICO) under number Z2865579.
Paydek ("we", "our", "us") is in the business of providing electronic payment services to individuals, businesses, and other entities. We are committed to respecting your privacy and any information that may disclose your identity ("Personal Data").
This privacy notice aims to inform you about how and why we collect, use, disclose, store and protect your Personal Data in connection with your use of our website, our mobile app, and any of our related services.
Please note that you do not have to transfer your information to us; however, if you do not, it will substantially limit your ability to use and enjoy our products and services.
Paydek means:
First Floor, 22 City Road
London, EC1Y 2AJ
United Kingdom
Paydek and its affiliates maintains relationships with third parties, under which they maintain, operate and administer a co-branded prepaid debit card program to facilitate Paydek"s payments.
Our website and our mobile app may, from time to time, contain links to and from the websites or other links or mobile apps of our partner networks and our affiliates. If you follow one of these links, please note that these links and destinations have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any of your information via these links or destinations.
Paydek gathers various types of information, including information that identifies or may identify you ("Personal Data"). We collect and use information that you voluntarily provide through our website, our mobile app, when you contact us, if you apply for employment with us, or if you use a service that integrates with us. We also collect and use information about you that is provided by third parties.
This may include:
- When an individual registers for an account with us, we will request information which includes the individual"s name, email address, physical address, country of residence, contact phone numbers, date of birth, tax identification number, employment information, and we may request bank account details and credit and/or debit card details;
- When a business or other entity registers for an account with us, we will request information from certain owners, directors and authorized individuals, including names, email addresses, physical addresses, contact phone numbers, dates of birth, and government issued IDs;
- Throughout our relationship with a customer, we may require a customer to provide additional information to verify an individual"s identity, address or other data to manage our risk and compliance functions and to adhere to applicable laws and regulations. We may also obtain information about individuals from third parties such as fraud prevention agencies and KYC (Know Your Customer) and AML (Anti Money Laundering) service providers to fulfil our legal obligations;
- If you choose to participate in a customer survey, we may ask for your name, email address and other information required by the particular survey;
- If you report a problem or submit a customer review, we may ask you to provide information such as your name, email address, and account number;
- When you visit our website, register for an account, or access your Paydek account through our website and/or mobile app, we collect information related to your device, such as your device"s IP address, location data, referring website, which of our website pages your device visited, and the time that your device visited our website. For further information, please read the "Cookies and Other Tracking Technologies" section below.
Paydek will use Personal Data in order to carry out our operation as a payment service provider, to conduct certain activities related to your use of our website and our mobile app, and to better service any account a customer maintains with us.
This may include:
- To enhance account administration, including following customer instructions, facilitating payments and transactions, and verifying or reconfirming the accuracy of information;
- To assist in providing other services or products requested by a customer;
- To ensure that we comply with all applicable laws and regulations, including tax, legal, reporting, and auditing obligations;
- To help detect, prevent and report potentially fraudulent, prohibited or illegal activities;
- To administer our business activities, including troubleshooting, fraud detection, data analysis, testing, research, marketing, statistical and survey purposes, and to keep our business, website, mobile app, accounts, and our systems operational and secure;
- To maintain our relationship and to comply with our obligations with our partners in order to maintain, operate, and administer our memberships with co-branded prepaid debit card programs;
- To ensure our website, our mobile app, content and services are as relevant and effective as possible, and to provide the best possible service and experience to our customers;
- Researching the demographics and behaviours of our customers;
Lawful Basis for Processing Personal Data
Paydek will only collect, process, or transfer your Personal Data for any of the following reasons:
- Performance of a contract
To enter into and fulfil a contract we have with you, including providing our services, sending you messages about your account and our services, answering your inquiries, and investigating and resolving any complaints.
- Compliance with a legal obligation
To comply with all legal obligations and regulations that apply to us and our customers, including record retention, customer identity confirmation, AML/BSA compliance, fraud prevention, tax reporting, fraud prevention, banking and financial institution laws and regulations, and the like.
- For the purposes of legitimate interests
To advance our legitimate interests or those of a third party in providing payment services, operating and improving our services, marketing our products and services to you and others, including conducting security reviews, testing, updates and maintenance to ensure our website, our mobile app and other services operate seamlessly for you, to manage our financial affairs and business risks, and to generally protect our customers and employees.
- Consent
Whenever you have given your consent to us to use or process your Personal Data. For example, you may inform us that you have an interest in a particular product or service, in which case we may inform you about those products and services, and those of our partners, by email or push notification, if we think it would be of interest to you (you can unsubscribe from these by email or via our mobile app) or to share information about you with companies we work with when we need your permission.
Automated Decision-Making and Profiling
We are a highly technical and innovative company that frequently utilises Automated Decision Making (ADM) and Profiling. For example, so that we can provide you with a fast and efficient service, we may use ADM to inform you of new product updates or features that may be useful to you, verify your identity documents, or to confirm the accuracy of the information you have provided to us with external credit reference agencies and fraud prevention agencies.
Paydek may share and disclose Personal Data in the following limited circumstances:
- With business partners (including member banks and other financial institution partners) that perform services on our behalf, provide co-branded services or assist in the provision of our services, including those that assist us in preparing and distributing prepaid cardholder communications and responding to cardholder inquiries.
- With third parties to provide statistical tracking and advertising effectiveness for our website and mobile app. These third parties are prohibited from using Personal Data for any other purpose.
- When required by law and/or government authorities
We may from time to time rent or sell non-identifying demographic information in the aggregate that does not contain Personal Data or information that can identify you specifically.
Your Privacy Rights
You have the following rights with regard to your Personal Data at Paydek:
- Right of access
You have the right of access, commonly referred to as subject access, which gives you the right to obtain a copy of your Personal Data and supplementary information.
- Right to withdraw consent
In the event that you"ve provided your consent to process your Personal Data, you have the right to withdraw that consent. To opt out of marketing, please send an email to dataprotection@paydek.com
- Right to rectification
We want to ensure that your Personal Data is accurate and up to date. If any of the information that you have provided to us changes (for example, if you change your email address or phone number), please provide the updated information by sending an email to dataprotection@paydek.com. You may ask us, or we may ask you, to correct information that you or we think is inaccurate, and you may also request that we delete information which is inaccurate.
- Right to erasure ("right to be forgotten")
You can request us to erase your Personal Data where there is no compelling reason to continue processing. This right only applies in certain circumstances; it is not a guaranteed or absolute right, and is subject to record retention laws and regulations that may prohibit us from complying with your request until a later date.
- Right to restriction of processing
You have the right in certain circumstances to request that we suspend processing your Personal Data. When we suspend processing Personal Data, we will still be permitted to store your Personal Data, but any further processing of this information will require your consent, subject to certain exemptions.
- Right to object
You have the right to object to our use of your Personal Data. However, where there are compelling legitimate grounds, including in connection with any legal claims or law enforcement orders, we may continue to process your Personal Data despite your objection.
- Right to data portability
You have the right to obtain your Personal Data that you have provided to us with your consent or which was necessary for us to provide you with our products and services in a format which enables you to transfer that Personal Data to another organization. You also have the right to have your Personal Data transferred by us directly to the other organization, if this is technically feasible.
- Right to object and automated individual decision-making
You have the right not to be subject to a Paydek decision based solely on automated processing (without human involvement) where that decision produces a legal result or otherwise significantly affects you. You can request that a Paydek employee or representatives participate in any such decision-making process.
- Right to complain to a supervisory authority
You have the right to the right to lodge a complaint with a regulatory supervisory authority.
Data Retention
Paydek is a regulated financial institution and is required by Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) laws, including the Fifth Money Laundering Directive (EU) 2018/843 (5MLD) to retain some of your Personal Data, including transactional data, for up to 5 years.
We may also retain Personal Data, as necessary, for the duration of our relevant relationship or activity with you. We may also retain Personal Data longer for legitimate reasons that include anti-money laundering or fraud monitoring and compliance, to defend against ongoing or potential legal claims, to analyse historical recordkeeping, or to comply with legal and regulatory obligations.
Please note, retention periods are subject to change, depending on where you live, and changes to legal and regulatory requirements.
International Data Transfers
Paydek may utilise external vendors in countries located both within the European Economic Area ("EEA") and outside the European Economic Area ("EEA"), to which we may transfer Personal Data from our offices in the United Kingdom (UK) and the European Economic Area ("EEA"). We have signed vendor data protection agreements with each vendor to ensure that they are contractually obligated to treat your Personal Data with the same privacy principles that we at Paydek uphold and in the same manner as detailed throughout this Privacy Notice.
If these vendors are not located in the UK, EEA or Switzerland, then we ensure standard contractual clauses are in place to guarantee the adequacy of cross-border transfers from our office in the UK and EEA.
Security
We use technical, organizational and administrative security measures to protect any Personal Data we hold, transmit, store or otherwise process from accidental or unlawful destruction, loss or alteration, or unauthorized disclosure or access.
Children
We do not knowingly collect or solicit Personal Data from anyone under the age of 18.
Cookies and Other Tracking Technologies
A cookie is a small piece of data (text file) that a website or mobile app asks to place on users" devices to remember information about them, such as your language preference or login information. Cookies placed by Paydek are called first-party cookies. We may also use third-party cookies from a domain other than www.Paydek.com for our advertising and marketing efforts and to understand how you browse our website or use our mobile app (for example, which pages you visit or how long you remain on each page or which features of our mobile app you use).
We use cookies and other tracking technologies for the following purposes:
- To help us and third parties obtain information about your visits to our website and mobile app
- To analyse your visiting patterns to improve our website and mobile app
- To deliver advertising, communications and content that are specific to your interests from Paydek and third parties on our website and third-party websites
- To remember your language and other preferences
- To help you obtain information
- To measure how many people use our website and mobile app and how they use it
- To keep our website and mobile app running efficiently
Our website is regularly scanned to maintain a list of cookies that is as accurate as possible. We classify cookies in the following categories:
- Strictly necessary cookies
You can opt out of each cookie category (except "strictly necessary" cookies) by clicking on the "Cookie Settings" link at the bottom of the page or by reviewing the Cookie Notice on our website.
By using our website or mobile app, you have the option to consent to the collection, use and storage of your Personal Data by Paydek.
Terms of Service
You may review our Terms of Service at https://www.paydek.com/legal/terms-of-service/
Updates to the Privacy Notice
We constantly strive to improve our website, our mobile app and our services. We recognize that data protection and data privacy is an ongoing responsibility, so we will update this Privacy Notice from time to time as we implement new practices or adopt new privacy policies. We will, for example, alert you of material changes by placing a notice on our website and our mobile app, and/or by sending you an email (if you have registered your email address with us) when we are required to do so by applicable law. You can see when this privacy notice was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Privacy Notice.
DEK-CO (UK) LTD d/b/a PAYDEK
First Floor, 22 City Road
London, EC1Y 2AJ
United Kingdom
Our Data Protection Officer
Harry Boje
If you have any questions or concerns regarding our privacy notice, please send a detailed message to our Data Protection Officer at dataprotection@paydek.com