Privacy Policy
September 2024
This privacy notice (“Privacy Notice”) explains how we process your personal data (“Personal Data”) while you use our services, including when you browse our website (“Website”), perform a transaction with us, or visit our stores (collectively, “Services”) , whether as a customer, a visitor and/or a user of our Website, or however you might otherwise interact with us (collectively, “you”, “your” or “users”). In this Privacy Notice, we also describe whether your Personal Data is shared with other parties and the mechanisms we have in place to protect your data.
We encourage you to regularly review this Privacy Notice and check the Website for any updates. Updates to this Privacy Notice will be published on our Website, and by continuing to deal with us, you agree to this Privacy Notice and any future modifications.
Where local law requires additional details to be included in this Privacy Notice, such information has been included in the Regional Privacy Notices section below.
Content
Regional Notices
What Personal Data is collected and why?
Notice to United States Consumers (CCPA)
How long do we keep Personal Data?
Description of Personal Data Rights
Frequently Asked Questions (FAQs)
How can I contact the company regarding my Data? To make any request or consultation, you may contact us by email to dpo@euroentworldwide.com
Who are we? We are epay, a subsidiary of Euronet Worldwide Inc.
What type of Personal Data is collected? We collect only the Personal Data necessary to provide you with the Service and to comply with applicable law.
Why do We collect Personal Data? We collect Personal Data for specific contractual and legal purposes. With your consent, we also collect data for additional purposes.
How long do we keep Personal Data? We keep Personal Data only for as long as necessary or as required by applicable law.
With whom we share Personal Data? We share Personal Data with other Euronet Group companies, legal authorities, and partners where necessary to meet regulatory requirements or contractual commitments.
Where do we store Personal Data? We store Personal Data in secure locations with strict security measures in place. If we need to transfer Personal Data to other locations, we take all necessary measures to comply with legal obligations and ensure a proper level of security.
What are your Personal Data rights? Depending on where you live, you may have rights in relation to your Personal Data under applicable law. A description of common Personal Data rights is set out in section 15 below.
1. What Personal Data is collected and why?
The categories, sources, and reason for collecting Personal Data are listed below. Where the collection of Personal Data is based on your consent, you may withdraw your consent at any time. We do not and will not “sell” or “share” Personal Data, as those terms are defined under applicable laws. We retain Personal Data for as long as reasonably necessary to provide the Services and meet our legal obligations.
If you have questions or concerns regarding the processing of your Personal Data, you may contact us any time at dpo@euronetworldwide.com
We collect Personal Data from the following sources:
- Directly from you through direct interactions and forms.
1.1. Types of Personal Data
a) Behavioral and Technical Information
IP address, internet, or other similar network, browsing, or search activity, behavioral information (to understand the way you behave while using our products and services), browser type and version, time zone setting, screen resolution settings, browser plug-in types and versions, operating system, and platform.
Our Cookie Policy is available here
Purpose for Processing
Legal Basis
To perform analytics to measure the use of our website and Services, including number of visits, average time spent on the Website, pages viewed, page interaction data (such as scrolling, clicks, and mouse-hovers), etc., and to improve the content we offer to you.
Consent
To undertake activities to verify or maintain the quality of the Service, and to improve, upgrade, or enhance the Service, including to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
Consent
Legitimate Interest
To help ensure the safety and security of our Website.
Consent
Legitimate Interest
To provide advertising and marketing, including measuring the impact of our emails.
Consent
To provide the Services, including to process the transaction.
Contractual obligation
b) Non-Identifiable Data
Whenever possible, we use data where you cannot be directly identified (such as anonymous demographic and usage data) rather than Personal Data (“non-identifiable data”). This nonidentifiable data may be used to improve our internal processes or delivery of services, without further notice to you.
We may use aggregate data for a variety of purposes, including to analyze, evaluate and improve our Services.
1.2 Accuracy of Personal Data
We are committed to keeping your Personal Data accurate and up to date. We take reasonable steps to ensure the accuracy of your Personal Data by ensuring that the latest Personal Data we have received is accurately recorded and when considered necessary, we run periodic checks and request that you update your Personal Data. From time to time, we may send you an email asking you to confirm and/or update your Personal Data. This communication is based on our legitimate interest and legal obligation to maintain accurate and up to date information.
If you notice that your Personal Data is not accurate, you may request a correction or update your information by sending an email to dpo@euronetworldwide.com
2. Legitimate Interest
When we use your Personal Data to pursue our legitimate interests, we will make every effort to match our interests with yours so that your Personal Data will only be used as permitted by relevant law, or when it will not adversely affect your rights. Upon request, customers may request information on any processing based on legitimate interest.
3. How long do we keep Personal Data?
Personal Data is kept for as long as it is necessary to provide the Services requested and to comply with applicable legal, accounting, or reporting obligations. The retention period is determined based on the applicable requirements and obligations, which may include:
- Legal and Regulatory Requirements: Your Personal Data is kept as long as necessary to comply with all our legal obligations including without limitation, commercial, tax and anti-money laundering laws and regulations. While we store your Personal Data only for the purposes of complying with legal obligations, your Personal Data will be restricted such that it cannot be used for any other purposes. While restricted, only when necessary, will your Personal Data be accessed. Whenever we receive a request for deletion, we will also maintain your Personal Data further to our legal obligations.
- Customer Service and Contractual relationship (administration of customer relationship, complaint handling, etc.): We will keep your Personal Data if you remain our customer. Once we consider our contractual relationship to be over, we will proceed to restrict your data to make it available only to comply with legal obligations as expressed above.
4. Do We disclose Personal Data?
epay´s disclosure of Personal Data for business purposes or to meet legal obligations are outlined below:
4.1. Euronet Group
Types of Personal Data
Purpose
Legal Basis
Behavioral and Technical Data
We disclose your Personal Data with Euronet and Euronet Group affiliates for our affiliates’ everyday business purposes and compliance with group obligations. As a result of a sale, acquisition, merger, or reorganization involving Euronet, a company within the Euronet Group, or any of their respective assets, we may transfer customer Personal Data to a third party. In doing so, we will take reasonable steps to ensure that their information is adequately protected. Your Personal Data is also disclosed to be able to provide you with customer service, regardless of when you require our help. To provide access to our 24/7 customer service, we must share your Personal Data with the Group affiliates.
Legal Obligation
Contractual Obligation
4.2. Third-Party Service Providers
Types of Personal Data
Purpose
Legal Basis
Behavioral and Technical Data
To advertisers or advertising networks and social media companies to place personalize placed advertisements in digital services and to adapt to consumer preferences.
Consent
*The legal meaning and list of “third-party service providers” may vary depending on the country you are based. For additional information regarding which providers have access and why they have access to your Personal Data you may reach us at dpo@euronetworldwide.com
4.3. Legal and Regulatory Authorities
Types of Personal Data
Purpose
Legal Basis
Financial Details
Transactional Data
Video surveillance
Identification Data
We may need to disclose your Personal Data (including Sensitive Personal Data, as described above) if requested by a legal authority. We may share your Personal Data with legal authorities to enforce or apply our Terms and Conditions or any other agreement or understanding we may have with you.
Legal Obligation
Contractual Obligation
5. Data Security
We are committed to protecting your Personal Data and have put in place commercially reasonable and appropriate safeguards to prevent any loss, abuse, and alteration of the information you have entrusted us. At Epay, we will always strive to ensure your Personal Data is well protected, in accordance with international best practices. We maintain this commitment to data security by implementing appropriate physical, electronic, and managerial measures to safeguard and secure your personal information.
To safeguard our systems from illegal access we use secure, cutting-edge physical and organizational security measures which are continuously enhanced to ensure the highest level of security in accordance with international best practices and cost efficiency. All Personal Data is kept in a secure location protected by firewalls and other sophisticated security mechanisms with limited administrative access.
Personnel who have access to your Personal Data as well as the processing activities surrounding your Personal Data are contractually bound to keep your data private and adhere to the Privacy Policy we have implemented in our organization.
We aim to achieve the highest standard of data protection by adopting industry-standard measures to protect your privacy.
6. Description of Personal Data Rights
Depending on where you live, your Personal Data Rights under applicable law may include:
- Right to Access: the right to request access to a copy of your Personal Data.
- Right to Correct Inaccuracies: the right to request correction of inaccuracies in your Personal Data.
- Right to Deletion: the right to request deletion of your Personal Data where certain conditions apply.
- Opt-Out Rights: the right to opt-out of the processing of Personal Data for the purposes of targeted advertising.
- Right to Restrict Processing: the right to restrict processing where certain conditions apply.
We will respond to your request as soon as possible and within the timeframe stated in the applicable law.
For applicable rights please refer to the Regional Privacy Notice section below.
To exercise any of your rights, you must send an email to dpo@euronetworldwide.com. To help protect your privacy and maintain security we will take necessary steps to verify your identity and may ask you to provide other details before granting you access to your Personal Data or initiating a modification of any Personal Data. When required, if we don’t have a copy of your ID or any legal valid document that proves your identity, we will not be able to answer your request.
Be aware that some rights may not be enforceable due to business necessities or legal obligations while providing you with the Service. Your rights may be limited to comply with other legal obligations such as anti-money laundering, contractual and compliance obligations. Notwithstanding that you will always be responded to when exercising any of the rights stated above and/or any additional right you may have depending on your jurisdiction. If your rights can’t be enforced, you will always receive a proper explanation.
7. Privacy Complaints
If you have a complaint regarding our processing of your Personal Data, you may contact us at dpo@euronetworldwide.com.
Depending on the applicable privacy law, you may have the right to make a complaint to a Data Protection Authority or other regulatory body if you believe we have failed to comply with our obligations under this Privacy Notice or the applicable law.
12. Regional Privacy Notices
8.1. Notice to United States Consumers
This Notice is provided to United States consumers and customers (including former customers) to meet the requirements of the federal Gramm-Leach-Bliley Act (“GLBA”), where applicable, related to the collection, disclosure, and protection of “nonpublic personal information” (“NPI”) as defined by the GLBA. For the purposes of this Notice, NPI means personally identifiable information about an individual that is collected by Us as a financial institution under the GLBA in connection with providing a financial product or service, unless the information is lawfully made publicly available. NPI collected by Us may include any:
- information an individual give Us to get a financial product or service.
- information We get about an individual from a transaction involving financial products or services (i.e., the fact that the individual is a customer/consumer of Epay, account numbers, payment history, etc.); or
- information We get about an individual in connection with providing a financial product or service (i.e., information from a consumer report or court record).
The categories of NPI that may be collected by Us are listed in section 1 of this Privacy Notice.
The categories of NPI that may be disclosed by Us are listed in section 9 of this Privacy Notice.
The categories of affiliates and nonaffiliated third parties to whom NPI is disclosed or may be disclosed in the future are listed in section 9 of this Privacy Notice. Where We disclose NPI to nonaffiliated third parties pursuant to the exceptions under the GLBA, all such disclosures are made as permitted by law. A “nonaffiliated third party” is any person except a financial institution’s affiliate or a person employed jointly by a financial institution and a company that is not the institution’s affiliate.
The categories of information disclosed and to whom under joint marketing/service provider exception of the Privacy Rule are listed in section 9 of this Privacy Notice.
If NPI may be disclosed to nonaffiliated third parties, and that disclosure does not fall within any of the exceptions of the Privacy Rule under the GLBA, consumers’ and customers’ have the right to opt out of these disclosures and an opt-out mechanism will be provided to the consumer or customer.
Notice of epay´s information sharing among Euronet Group and its affiliates is provided in section 9 of this Privacy Notice in accordance with the Fair Credit Reporting Act.
epay´s policies and practices with respect to protecting the confidentiality and security of NPI are set out in section 11 of this Privacy Notice.
Internal Appeals Process: If you receive notice from us that your Personal Data rights request has been refused, you may appeal the refusal within a reasonable period after receiving the notice by sending an email to dpo@euronetworldwide.com.
California Consumers
In accordance with the California Consumer Privacy Act, residents of California may exercise the following rights:
Right of No Retaliation Following opt Out or Exercise of Other Rights
Right to Access
Right to Correct Inaccuracies
Right to Deletion
Right to opt Out of Sale or Sharing of Personal Data for cross-contextual behavioral advertising purposes