WAY 2 VAT LIMITED
Way 2 Vat Limited. (“Way 2 Vat” or “us”) is committed to your right to privacy.
We value your privacy and your rights under the Data Protection Legislation (incl. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (the “GDPR”), the UK-GDPR and any other local data protection law of the countries where Way 2 Vat operates.
If you choose to use the Services, interact with the Website, or provide data to us otherwise, you explicitly agree to the use of such data in accordance with this Privacy Notice. You may not use the Services and the Website or submit any data through them if you do not agree to any of the terms hereunder. This Privacy Notice shall not be construed in any manner to derogate from the Terms or any other agreement or understanding between Way 2 Vat and you.
Terms not defined in this Privacy Notice will have the meaning ascribed to them in the Terms.
A separate agreement governs processing of any information, files, and personal data provided to us by our Users or clients and uploaded by any of them to our systems (the “Data Processing Agreement”).
- You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.
- Our Services are intended for Users over the age of 16 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to use the Services. If you are under such age you should cease to use the Services immediately.
- You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted or disabled.
- We do not sell, trade, or rent Users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances as specified herein.
- Upon your submission of an application for an Account, you should also review the respective privacy policies and notices published by the Issuer with respect to the treatment of any personal information provided in relation to its services.
- We have appointed a Data Protection Officer (“DPO”), who shall be responsible to oversee our data protection compliance, answer your concerns and assist you in exercising your rights under the GDPR. Our DPO is available to contact at:
- Address: 35 Ballards Lane, London, England, N31XW
- E-mail: firstname.lastname@example.org
- Contact person: Guy Stolero
- What is Personal Data and what data is collected about me by Way 2 Vat?
“Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.
We collect non-Personal Data regarding Users concerning their use of the Website and Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Services, device identifiers, and other technical information regarding the device used to access the Services, such as model, operating system, etc.
- When you apply to set up an Account, set up an Administrator or User in an Account, use the Services in order to pay for purchases through the Account and Card(s) or communicate with us for any purpose, certain Personal Data will be collected about you, including contact information (such as full name, address, email address, phone number, Company details, your position in the Company, etc.), Card details, transaction information billing information (such as credit cards information), your passport, ID card, or driving license, IP address and your picture in addition to your other identification details as shall be required by our KYC procedure. This information may be requested by us directly or transferred to us by the merchant you are making the purchase from, depending on the process of implementation of the Way 2 Vat solution in the merchant’s payment process. Some of the requested information is voluntary so you can choose not to provide it, but this might result in us not able to provide you with the Services or part of them.
- The Issuer will process your data for the purposes of the provision of its services that are subject to its Cards Terms and Conditions and we will process your data in order to perform our duties as Agent of the respective Issuer and to provide you with the Services related to your Card(s).
- If you register as a merchant for our Services, we will collect and process the information requested of you during the registration process, such as region, business information, contact person information, bank information, etc.
- We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the Website or collected by us, please inform us immediately.
- We shall not use any Personal Data, unless it has been voluntarily provided, entered or uploaded by you personally. You are not allowed to enter Personal Data of any 3rd party, without due authorization by such 3rd party.
Please note, that the Website and/or Services may contain links to other websites maintained by third parties, which may not be governed by this Privacy Notice. This Privacy Notice does not be apply to the practices of entities which are not controlled by Way 2 Vat.
- Non-Personal Data. Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our Website and Services, including among others, in order to measure and understand the level of engagement to our services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Services and for developing new services and features.
- Personal Data.Personal Data is used only for the following limited purposes:
- To provide you with the Services, process transactions, and collect fees.
- To resolve any disputes, communicate with you regarding customer service and support issues, and to respond to questions or comments and help resolve any problems, including by email or phone.
- To prevent potentially prohibited or illegal activities, and enforce our Terms.
- To protect the security or integrity of our databases and the Services, and to take precautions against legal liability.
- To improve the Services, and to develop new features, products and services.
- To improve your experience on the Website and customize our Services to your interests, including by way of targeted advertising.
- For the purposes of our legitimate interests, to the extent not overridden by the rights and freedoms of natural persons, as permitted under applicable law.
- Under the AML and CFT regulations, we are obligated to monitor your card and/or bank payments into and out of your Account to make sure they are not involved by any means in money laundering, financing of terrorism, fraud or bypassing imposed sanctions.
- To provide updates with respect to material changes to this Privacy Notice or our Terms and Conditions.
- To provide you with information about our products and services that you might be interested in your capacity as User or Administrator or gave your consent to same under different circumstances. We may process your Personal Data provided by you for direct marketing activities such as sending marketing communications, offers and other similar news and updates.
- To exercise or protect our rights and interests as well of those of the Issuer or Company to initiate, handle or defence legal claims.
Yes, we use data files such as cookies, pixel tags, “Flash cookies,” or other local storage files provided by your browser or associated applications (“Cookies”). We use these technologies in order to recognize you as a customer; customize our Services, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our sites and Way 2 Vat Services.
We use both session and persistent Cookies. Session Cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent Cookies remain on your device until you erase them or they expire.
You may also encounter Way 2 Vat Cookies on websites that we do not control. Likewise, certain third parties may place their own Cookies in the Website and Services. Such third party Cookies are not subject to our control and this Notice does not cover them.
You may at any time program your browser to block cookies, but please be aware that such blocking may prevent us from providing some or all of the Services to you. These cookies help us track how visitors use the Website and our Services.
- Reviewing and amending your Personal Data. If you are a merchant, you may review the information included in your account on the Website. If you are a buyer, you may send us a request in connection with reviewing your Personal Data to: Support@spendcard.app In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the Website, as applicable to you.
- Right of erasure and restriction. You may also be entitled request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
- Portability of Personal Data. To the extent relevant to you and to the Services, you may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
- Retention of Data. We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfil the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analysis and development of the Services; and (iv) to comply with applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.
WE DO NOT SELL OR RENT ANY OF YOUR PERSONAL DATA TO NON-AFFILIATED THIRD PARTIES FOR THEIR MARKETING PURPOSES.
- Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and clients.
- We share Personal Data only under the following limited circumstances:
- With partners who are an integral part of our Services, such as the merchant you placed a purchase with, credit card processer, banking institution, etc.
- With trusted 3rd parties who assist us in operating the Services and conducting our business, such as fraud prevention, bill collection, account maintenance, marketing and technology services.
- For personalizing your experience of the Services, including by way of targeted advertising on the Website.
- As necessary to help detect and prevent potentially illegal acts and fraud, and to guide decisions about the products, services and communications.
- Credit bureaus and collection agencies to report account information, as permitted by law.
- To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
- Other third parties with your consent or direction to do so.
- With the Company and Administrators. Personal Data stored into the Account, such as the data about Administrators, Users, Cardholders, Services, expenses and other details uploaded or generated within the Account, are available to the Company and Administrators who have access to the Account.
- With an Issuer in order to provide and monitor the Services to you and the Company.
- Certain processing activities conducted by us are based on the necessity of such activities for the performance of our Services and the contract between us and our Users. Further, as a registered Agent of licensed electronic money institutions (EMIs), we have obligations under the AML and CFT regulations to process your personal data.
- Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of natural persons which require protection of Personal Data.
- There may be certain processing activities based on your consent. In connection with such activities, you may rescind your consent, by sending us an email to: Support@spendcard.app Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services.
Our databases are currently located in the United States. Some of our processing activities are made in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.
Any other transfer of Personal Data originating from the EU to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users’ rights.
Way 2 Vat may send you offers that may be of special interest to you via email or SMS. You may unsubscribe from receiving such communications at any time, by sending us a notification to: Support@spendcard.app for following the instructions for unsubscribing included in such communications.
We may also engage with third parties to track and report performance of advertising and marketing campaigns to and from Way 2 Vat and third party web sites. We may combine your information with information we collect from third parties and use it to improve and personalize our Services, content, and advertising.
Our Website is a general audience Website, which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.
The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you.
If you have any questions or concerns regarding privacy issues, please send us a detailed message to Support@spendcard.app and we will make every effort to resolve your concerns without delay.
Way 2 Vat may, at any time and from time to time, modify this Privacy Notice. Modifications to this Privacy Notice will be posted on the Website, and shall be effective as of the date in which they are posted on the Website.
You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.