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Privacy policy

Who we are

PagoFX S.A. (hereinafter, “PagoFX”, “we” or “us”) is the controller of the personal data you provide to us.

We have tried to make this Privacy Policy as short and clear as possible, but if any of the topics tackled herein is not clear enough, or if you would need additional information, you can get in contact with us at any time through any of the following means:

– PagoFX’s postal address: 85B, Avenue des Nerviens, 1040 Etterbeek (Brussels), Belgium

– PagoFX’s e-mail: privacy@pagofx.com

– Live chat through PagoFX’s website

You may also contact our Data Protection Officer (hereinafter, the “DPO”) at the postal address indicated above or by email at dpo@pagofx.com

This Policy applies to PagoFX’s mobile app, PagoFX’s website, as well as to any other platform through which you may get our services.

Purposes of processing and legal basis

We will process your personal data for the purposes described below:

  • To manage your registration request: We will process your personal data to deal with the registration process for which we will ask you for your email address to send you an email communication in order to validate your account.

The processing of your personal data is carried out for the execution of PagoFX Terms of Service.

In the case of registration of a company or legal entity in our service, we will process the personal data of the legal representatives provided in order to proceed with the entity registration request. Accordingly, PagoFX will request the email of such person to validate the company account.

PagoFX will only process representative’s personal data for this purpose based on its legitimate interest.

  • To make effective the subscription for the services and to verify your identity for using our Services: Once you have validated your email address, PagoFX needs more detailed information about you. Accordingly, you shall provide to us some personal data (name and surname, data of birth, postal address, city, residential address, postcode, country of residence and nationality) through the form that we will put at your disposal. If applicable, PagoFX may request personal data concerning financial information, to comply with the fraud prevention, anti-money laundering and counter terrorism financing regulations.

When you have completed such form, we will need to verify your identity, to which end you will need to provide a photo of an identity document (like your passport, driving license, national identity document) of which we will take a photo so that we can verify the correspondence between your face and the one that appears on your identity document. In addition, we will carry out a video-identification in compliance with the Spanish regulations on the prevention of money laundering and financing of terrorism.

PagoFX carries out the processing of your personal data for the execution of the Terms of Service.

In the case of companies, the identification and contact details of the legal representatives will be processed in order to proceed with the subscription of the entity for PagoFX services. In fact, legal representatives will be subject to KYC processes, including verifying their identity for which PagoFX need to obtain a copy of their ID document, a selfie and any other information needed to identify them.

PagoFX will only process representative’s personal data for this purpose based on its legitimate interest.

  • To provide you the Services hired with PagoFX: Once PagoFX checks and validates all the documentation sent by you, you will be able to enjoy the financial Services provided by PagoFX for making international payments.

Accordingly, and in order to provide such Services, PagoFX will also collect personal data from the recipient(s) who you/the company, if applicable are sending money to (first name, last name, recipient’s bank details), as well as the card details, since it will be necessary in order to make the transaction.

As part of the Service, you will have a private section where you can make any changes about your personal information and manage your privacy preferences.

PagoFX carries out the processing of your personal data for the execution of the Terms of Service. The representative’s personal data processed in this context will be used by PagoFX based on its legitimate interest.

  • To send you payments-related communications: We will process your personal data (this case may include also representative’s data, if applicable) to keep you informed about the transactions details made by you through the APP or the Website.

We carry out the processing of your personal data in compliance with legal obligations that must be fulfilled by PagoFX under payments regulations.
PagoFX will only process representative’s personal data for this purpose based on its legitimate interest.

  • To deal with the questions you set forth through live chat: We will process your personal data (this case may include also representative’s data, if applicable)  to manage the queries and/or concerns expressed through the live chat that we are offering within the APP or website or by any other means.

By contacting PagoFX through the live chat, or by any other channel, you express your acceptance to the processing of your personal data for the purposes described in this item.

  • To send you quality surveys regarding PagoFX products and services: We may process your personal data (this case may include also representative’s data, if applicable) for sending you quality surveys by electronic means about PagoFX products and services hired by you, in order to receive your feedback on the provision of such services and with the purpose of improving the matters that you highlight in the quality survey.

PagoFX carries out the processing described in this point on the basis on its legitimate interest. Notwithstanding, you can exercise your right to object if you do not want to receive more quality surveys.

  • To send you commercial communications about PagoFX’s Services: We may send you commercial communications by electronic means (e-mail, push notifications and SMS/MMS messages) related with products and services offered by PagoFX, which are similar to the Services hired by you at the beginning. This case may include also representative’s data, if applicable.

PagoFX will only process your personal data for this purpose based on its legitimate interest, although you can express your objection to this processing at any time.    

  • To transfer your personal data to entities of Santander Group for commercial purposes: PagoFX may transfer your personal data to other Santander Group companies for commercial purposes, so that such entities may send you commercial or promotional communications of their products and services by electronic means. This case may include also representative’s data, if applicable.

This processing will only be carried out if PagoFX have your prior and express consent, which will be required at the time of registration in the APP or in the Website. If you give your consent for this purpose, you can remove it whenever you want.

  • To deal with judicial or administrative proceedings: If appropriate, PagoFX may eventually process your personal data (this case may include also representative’s data, if applicable) to deal with judicial or administrative proceedings that could be related with the provision of Services, within the limits established by the applicable procedural regulations.

PagoFX may process your personal data following the legal obligations established by the procedural law.

  • To deal with the complaints submitted: PagoFX may process your personal data for managing claims (this case may include also representative’s data, if applicable), if any, filed by you and for offering an adequate solution to solve it.

This data processing is necessary for the execution of the Terms of Service. PagoFX will only process representative’s personal data for this purpose based on its legitimate interest.

  • To comply with the fraud prevention, anti-money laundering and counter terrorism financing regulations: We will process your personal data to verify your identity, to monitor the transactions you make through the APP or website, as well as to submit reports to the Belgian competent authority.

In this case, we will process your personal data in compliance with legal obligations to which PagoFX is subject (fraud prevention, anti-money laundering and counter terrorism financing regulations).

This processing activity will be applicable only to clients who are natural persons.

  • To verify the transactions made in the APP for strict fraud prevention (including automated processing)

The processing of data regarding to fraud prevention (including automated processing) will be carried out based on our legitimate interest to verify your identity and to monitor the transactions you may do through the APP, in order to protect our business and to comply with the applicable legal requirements.

In accordance with the above, your personal data may be transferred to fraud prevention agencies. This data processing will be carried out based on a legitimate interest of PagoFX, in order to protect our business and to comply with the applicable legal requirements.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

As part of the processing of your personal data for fraud prevention purposes, PagoFX may use automated means to know if you represent a risk in the context of fraud prevention by analysing your behaviour according to previous transactions or actions made by you. In any case, you have the corresponding rights regarding to automated individual decision-making (please see point “What are your rights”).

This processing activity will be applicable only to clients who are natural persons.

  • To comply with the Payment Services regulations (PSD2): PagoFX will also process your personal data (this case may include also representative’s data, if applicable) for complying with the legal requirements provided by the Payment Services regulations, especially for applying the security measures required by such legal instrument.
  • To perform IT maintenance services and backups: PagoFX will use your personal data, based on our legitimate interest, for the maintenance of the APP or website, as well as for making the necessary backups of the systems.

How we obtain your personal data

We process the personal data that you have directly provided to us by one of the following means:

  • You have previously sent an information request to us.
  • You have subscribed to our e-newsletter.
  • You have completed a PagoFX form with your personal data.

If you give us someone else’s personal data, we will inform such persons that we have obtained their data from you. In any case, and given that PagoFX may process third party data provided by you, because of the provision of Services, you undertake to obtain consent, if appropriate, and inform such third party of the provisions contained herein on data protection.

How long we keep your personal data

We keep your personal data as long as the company needs it for the purposes for which it was collected, taking into account local laws and contractual obligations. When we will no longer need such personal data, we will duly block it during applicable statutes of limitation and/or retention periods set forth by law and we will only be able to process it in order to:

  • Comply with the legal obligations that may be applicable; and
  • Make the personal data available to the competent Public Administrations, Courts and Tribunals or the Public Prosecutor’s Office.

When such retention periods end, we will physically destroy your personal data.

How we keep your data secured

We maintain reasonable security measures to safeguard your personal data from loss, interference, misuse, unauthorised access, disclosure, alteration or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and it is accurate, complete and up-to-date.

When we share your personal data

The list below shows who we share your information with and why.

  • In some circumstances, we are legally obliged to share your personal data. For example, under a court order or when we receive an order from competent supervisory authorities in handling complaints or investigations or when we submit reports to the competent authorities. In any of such scenarios, we will have a lawful basis on which to share the data.
  • For providing the Services, we may transfer your personal data, including the recipient’s personal data, to the financial collaborating entities to which the international payment has been sent. In addition, PagoFX is allowed to make such transfer of personal data to law enforcement agencies in order to detect, investigate and prevent crime (we or any fraud prevention agency may transfer your information to law enforcement agencies).
  • The Customer hereby acknowledges, and when required by applicable data protection regulation expressly consents, the disclosure of his/her personal data to other Santander Group companies, along with any relevant transactions-related information, that allows such companies to comply with (i) the Group´s Financial Crime Compliance internal policies, (ii) its legal obligations relating to the anti-money laundering and counter terrorism financing regulations and (iii) its regulatory reporting to the supervisory authorities.
  • In case you have given your consent to PagoFX, we may communicate your personal data to other companies of Santander Group so that they can send you commercial communications about their products and services.
  • We use data processors, i.e., third parties who provide services to PagoFX and may have access to your personal data on our behalf. We have contracts in place with our data processors, which means that they cannot do anything with your personal data unless we have instructed them to do it. They will not share your personal data with any additional entity apart from PagoFX.

PagoFX has adopted the appropriate measures to contract with data processors that meet all the requirements and guarantees required by the data protection regulations. Accordingly, the data processors will apply the technical and organizational security measures that will guarantee the protection of your personal data.

For instance, we will make use of the services offered by data processors that carry out their activity, including but not limited, in the following sectors: cloud hosting services, IT and maintenance services, logistics services, legal advice and financial services, homologation of suppliers, instant messaging service providers, customer support, customer relationship management, transaction monitoring services in compliance with fraud prevention and anti-money laundering and counter terrorism financing regulations. For more information about PagoFX’s data processors, please click here.

Among such data processors, Salesforce Inc. is located outside the European Economic Area, in the United States. We inform you that we use Salesforce Inc. platform for the customer record management (CRM), which allows PagoFX to contact with you and to keep you updated on news that may be of interest to you. In general terms, international transfers of data outside the European Union will be carried out in accordance with the provisions of the applicable data protection regulations.

What are your rights

Under data protection law, you have the following rights:

  • Right of access: You have the right to ask PagoFX for copies of your personal data.
  • Right to rectification: You have the right to ask PagoFX to rectify personal data relating to you that may be inaccurate. You also have the right to ask PagoFX to complete personal data that may be incomplete.
  • Right to erasure: You have the right to ask PagoFX to erase your personal data in certain circumstances.
  • Right to restriction of processing: You have the right to ask PagoFX to restrict the processing of your personal data in certain circumstances.
  • Right to object to processing: You have the right to object at any time to process your personal data for direct marketing, based on legitimate interest, which includes profiling to the extent that it is related to such direct marketing.
  • Right to data portability: This only right applies to personal data that you have given to PagoFX. You have the right to ask that PagoFX transfers the data to another organisation. The right only applies if we are processing personal data based on your consent or in talks about entering into a contract and the processing is automated.
  • Right to object and automated individual decision making: You have the right to not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal effects concerning you. Therefore, you will have the right to obtain human intervention on the part of PagoFX and to express your point of view and to contest our decision in a reasoned manner if you believe that it is wrong.

You can exercise the personal data rights indicated above, by sending a communication to PagoFX’s privacy team by the means and to the addresses detailed at the beginning of this policy, providing a copy of a personal identification document.

How to contact us about this notice or make a complaint

We work to high standards when it comes to processing your personal data. If you have queries or concerns, please contact with the company at privacy@pagofx.com or through the live chat through PagoFX’s APP or website and we will answer the questions. If you are not satisfied with our response, or if you think that the company is not processing your personal data in accordance with the law, you can submit a complaint to the Belgian Data Protection Authority, Rue de la presse 35, 1000 Brussels, or visiting its website: https://www.dataprotectionauthority.be/