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Privacy Policy

Rapyd Financial Network (2016) Ltd. and Rapyd Europe hf. (together with certain other Rapyd group companies – “Rapyd”, “we”, “our” or “us”) provides a fintech-as-a-service platform (“Platform”) operating the world’s largest local payment network, which allows for the integration of local payments methods into digital applications from one single API, and the effective performance of cross-jurisdictional transactions (“Services”).

Our Platform and Services are operated through Rapyd API and business Portals used by our merchants (available at: https://sandbox.rapyd.net/ and at https://dashboard.rapyd.net/).

We respect the privacy of our Site visitors (available at: at www.rapyd.net – “Visitors”), our merchants (“Merchants”), and the personnel of our infrastructure partners and gateways (“Gateways”; and collectively – “you”) as well as the Merchant’s and Gateway’s end-users and Rapyd’s direct individual users (collectively “End-Users”), and are strongly committed to making our practices regarding their personal data transparent and fair.

This Privacy Policy describes how we collect, store, use and disclose the following types of personal data:

  1. End-Users relating to Individuals who transact with Merchants through  Gateways by use of Rapyd’s services.
  2. Merchants relating to Individuals or businesses who collect payment from End-Users with use of Rapyd’s services.
  3. Gateways relating to Entities which process payments between End-Users and Merchants on Rapyd’s behalf.
  4. Sites Usage, Customer Relationship Management (“CRM”) & Prospect Data relating to visitors of our website, participants at our events, Customers, partners, and any prospective Customers, partners or candidate who visits or otherwise interacts with any of our websites, online ads and content, emails or other communications under our control (“Rapyd Sites” or “Sites”).

The Privacy Policy applies whenever you visit, interact with us or otherwise access or use any of our Services. Specifically, this Privacy Policy describes our practices regarding:

  1. Data Collection
  2. Data Uses
  3. Data Location and Retention
  4. Data Sharing
  5. Cookies and Tracking Technologies
  6. Communications
  7. Data Security
  8. Data Subject Rights
  9. Data Controller/Processor
  10. Additional Notices

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services.

You are not legally required to provide us with any Personal Data (defined below), but without it we will not be able to provide you with the full range of Services or with the best user experience when using our Services.

1. Data Collection

We collect Personal Data regarding our Visitors, End-Users, Gateways and Merchants. We also collect Personal Data of individuals on Merchants’ or Gateway’s behalf as they and their End-Users use our Services through various Gateways and through the Portals. Such data is typically collected and generated through the End-User’s interaction with our Services, through automatic means, directly from such Merchant, Gateway or End-User, or from other third parties.

Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed data, will be deemed as “Personal Data”):

(i) End-User Data: we collect the following information relating to End-Users:

  • Contact information: such as first and last name, email address, home address, date of birth, (mobile) phone number.
  • KYC (Know Your Customer) Information: In certain circumstances, Rapyd may process a copy of an End-User’s current ID (such as a national ID or passport), nationality, driver’s license, a frontal facial picture, and/or a recent utility bill.
  • Financial Information: such as bank and billing account details, credit card information, as well as information regarding the End-User’s transaction with the Merchant.
  • Digital Wallet Information: such as digital wallet number and information regarding digital wallet transactions.
  • Usage Information: such as connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, IP addresses, device and mobile app data (such as type, OS, device ID, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on the device.

We process “End-User Data” on behalf of Merchants as their “Data Processor”. For more information on this distinction see section 9 below.

(ii) Merchant Data: we collect the following information regarding Merchants who are individuals, or information regarding the directors, shareholders and Ultimate Beneficial Owners if the Merchant is a corporation:

  • Contact information: such as first and last name, email address, home address, date of birth, (mobile) phone number.
  • KYC or KYB (Know your Business) Information: In certain circumstances, Rapyd may process a copy of a Merchant’s current ID (such as a national ID or passport), driver’s license, a frontal facial picture, nationality, and/or a recent utility bill.
  • Account Data: such as company name and position, account login credentials (usernames and hashed passwords), as well as any other data you choose to provide when you use our Services, create a user account or contact us.
  • Financial Information: such as bank and billing account details, credit card information, as well as information regarding the Merchant’s transaction with an End-User.
  • Digital Wallet information: such as digital wallet number and information regarding digital wallet transactions.
  • Usage Information: such as connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, IP addresses, device and mobile app data (such as type, OS, device ID, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on the device.

(iii) Gateway Data: we collect full name, email address, job title and other contact information regarding Gateway personnel.

(iv) Sites Usage, CRM & Prospect Data: we may collect and generate the following types of information our website Visitors, Merchants, partners and prospective Merchants (collectively, “Non-Services Related Data”).

  • Sites Usage Data: connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like device type, OS, device ID, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on our Sites and/or a user’s device;
  • Business Account Data: contact details, contractual and billing details relating to Merchants and our partners, which may also contain the details of their internal focal persons who directly engage with Rapyd on behalf of their organization (e.g. the account administrators, billing contacts and authorized signatories on behalf of Merchants or our partners, as well as the needs and preferences of Merchants or our partners, as identified to us or recognized via our engagement with them);

CRM and Prospective Customer Data: contact and business details, our communications with Merchants and prospective Merchants (correspondences, call and video recordings, call transcripts, and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement.

2. Data Uses

We use Personal Data as necessary for the performance of our Services and in reliance on the following legal bases:

End-User Data, Merchant Data & Gateway Data
Purpose Legal basis for processing
Providing Merchants with our Services Merchant assumes the role of a ‘data controller’ and Rapyd that of a ‘data processor’. As such the legal basis is established by the Merchant.
To comply with applicable laws and regulations, including by performing KYC/KYB inquiries and compliance checks
  • To the extent that the legal obligation to process Personal Data for the purpose of carrying out KYC/KYB checks is placed on the Merchant, and collected by Rapyd as part of the Service provided to Merchants (e.g. via our Rapyd Verify service), then Merchant assumes the role of a ‘data controller’ and Rapyd that of a ‘data processor’. As such the legal basis is established by the Merchant.
  • To the extent that Rapyd is required to process Personal Data as part of its KYC/KYB checks, the legal basis is compliance with legal obligations
Providing payment services in partnership with Gateways
  • Performance of a contract
  • Legitimate Interest
  • Compliance with a legal obligation
To create aggregated data, anonymized or pseudonymized data and/or De-identified Data Data processing instructions as provided by the Merchant as the ‘data controller’.
De-identified End-User Data & Merchant Data
Purpose Legal basis for processing
To support and enhance our data security measures, including for preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.
  • Legitimate Interest
  • Compliance with legal obligations
To create aggregated data, inferred non-Personal Data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose.
  • Legitimate Interest
User, Sites, CRM & Prospect Data
Purpose Legal basis for processing
To facilitate, operate, and provide our Service
  • Legitimate Interest
  • Performance of a Contract
To authenticate the identity of Merchants, Gateways and End-Users, and to allow them access to our Services
  • Legitimate Interest
  • Performance of a Contract
To provide our Visitors, Merchants and End-Users with assistance and support
  • Legitimate Interest
  • Performance of a Contract
To evaluate and develop new features, technologies, and improvements to the Service
  • Legitimate Interest
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications
  • Legitimate Interest
To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences
  • Legitimate Interest
To contact our Visitors, Gateways and Merchants with general or personalized messages and communications, as further described under Section 6 below; and to facilitate, sponsor and offer certain events and promotions;
  • Legitimate Interest
  • Consent
To facilitate, sponsor and offer certain events, contests and promotions.
  • Legitimate Interest
  • Consent
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.
  • Legitimate Interest
  • Performance of a Contract

If you reside or are using the Services (i) in a territory governed by privacy laws which determine that “consent” is the only or most appropriate legal basis for processing Personal Data (in general, or specifically with respect to the types of Personal Data you choose to share via the Service), your acceptance of our Terms of Service and of this Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Privacy Policy. If you wish to revoke such consent, please contact us by email at privacy@rapyd.net.

We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).

When you onboard as a new merchant to our platform, we are required to collect information and documentation in order to comply with anti-money laundering laws. After you provide this information, our system evaluates, based on preset criteria, whether we can approve your application to be registered as a merchant and either accepts or rejects your application, or otherwise sends it for further review. The types of factors involved in this decision are the type of establishment you have, whether you are on any AML blacklists, your country of origin and other relevant criteria. If you have any questions about this process or a decision that was applied to you, you can contact us via privacy@rapyd.net

3. Data Location and Retention

Data Location: Given the global nature of our Services, your Personal Data may be maintained, processed and stored by our authorized affiliates and Service Providers (defined below) in the United States of America (U.S.), the State of Israel, Singapore, the European Union and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Rapyd and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

Data Retention: We will retain your Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.

We retain a Merchant personnel’s Account Data in accordance with the instructions of their organization (the Merchant), or for as long as their account is active, and we have not been notified otherwise, or as long as we consider necessary for the purposes described herein.

We retain Visitors’ Personal Data for as long as reasonably necessary in order to maintain and expand our relationship with them and to provide them with our Services.

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at privacy@rapyd.net.

4. Data Sharing

Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own, namely – hosting, data analytics, consulting, support, marketing and advertising, data and cyber security, user engagement, instant messaging; as well as our business, financial, compliance and legal advisors (collectively, “Service Providers”). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.

Sharing Personal Data with Merchants and Gateways: We may share the Personal Data of a Merchant and/or its End-Users with such Merchant and the Gateway(s) involved in their transactions, as well as a Gateway’s End-User with such Gateway. Rapyd is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Merchant or Gateway, that themselves may act as the “Data Controller” of such data (as further described in Section 9 below).

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Rapyd, any of the Merchants, Gateways, End-Users, or any members of the general public.

Rapyd Subsidiaries and Affiliated Companies: We may share Personal Data internally within Rapyd’s group of subsidiaries and affiliates for the purposes described in this Privacy Policy. In addition, should Rapyd or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of all or part of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, Rapyd may share your Personal Data in additional manners, such as pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

5. Cookies and Tracking Technologies

Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.

A cookie is a small text file that is placed, for example, to collect data about activity on our Site. Some cookies and other similar technologies serve to recall Personal Data, such as an IP address, that was previously indicated by the Visitor.

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser and recommend the use of cookies for an optimal user experience of our Services, most browsers allow you to control cookies, including whether to accept them or to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. You can read the complete Rapyd Cookie Policy here.

We also use analytics tools such as Google Analytics. These tools help us understand your behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our google analytics is available at: www.google.com/policies/privacy/partners/;

Further information about your option to opt-out of google analytics services is available at: https://tools.google.com/dlpage/gaoptout.

Please note that if you get a new computer or device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

6. Communications

Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-reset notices, etc. We may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.

Notifications and Promotional Communications: We may also contact you with promotional messages (such as newsletters, special offers and sales, new product announcements, etc.) or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone or e-mail), through the Services, or through our marketing campaigns on any other sites.

If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to privacy@rapyd.net, changing your communications preferences in your account, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

7. Data Security

In order to protect your Personal Data held with us and our Service Providers, we use industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.

8. Data Subject Rights

If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as the right to request access to, or rectification or erasure of your Personal Data held with Rapyd, or to restrict or object to such Personal Data’s processing, or to port such Personal Data or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by email at privacy@rapyd.net.

Rapyd requests that all Merchants and Gateways provide adequate notice (for example through a privacy policy) to their End-Users of their use of Rapyd’s Services and of their and our processing of Personal Data for such purposes, and that such notice comply with all applicable laws. Rapyd provides all Merchants with the ability to publish on their website or through their mobile application an option for their End-Users to exclude themselves from tracking by the Services. For more information on the Merchant’s or Gateway’s privacy practices please visit their respective website and privacy policy.

If you would like to make any requests or queries regarding Personal Data which we process on a Gateway or Merchant’s behalf, please contact such Merchant or Gateway directly also.

Please note that once you contact us by e-mail regarding your data subject rights, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.

9. Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or the “business” under the CCPA), who determines the purposes and means of processing; and the “Data Processor” (or the “service provider” under the CCPA), who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Rapyd is the “Data Controller” of the following types of Personal Data:

  1. Merchant Data;
  2. Non-Services Related Data;
  3. KYC or KYB Information, where: (i) Rapyd has a legal obligation to carry out its own KYC/KYB checks, or (ii) Rapyd has a legal requirement to process Personal Data when carrying out a KYC/KYB check on behalf of a Merchant.

and assumes responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy.

For the avoidance of doubt, Rapyd and the Gateways will be independent Data Controllers of Personal Data shared by Rapyd in order to facilitate the payment process.

Rapyd is the “Data Processor” of End-User Data, which we process on behalf of our Merchants acting as Data Controller, as well as processing KYC/KYB data to the extent that the legal obligation to process Personal Data is placed on the Merchant, and collected by Rapyd as part of the Service provided to Merchants (e.g. via our Rapyd Verify service)in accordance with its reasonable instructions, subject to our Data Processing Addendum  with such Merchant (to the extent applicable) and other commercial agreements. The Merchant will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).

If you would like to make any requests or queries regarding your Personal Data (see Section 8), we encourage you to also contact such Merchants and Gateways involved in your transaction(s) directly and independently from your contacting of Rapyd. Rapyd may, but is in no way obligated to, forward you requests or queries to such Merchants and Gateways we believe to be involved in the processing of your Personal Data.

10. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is so published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website or service you visit. This Privacy Policy applies only to our Services.

Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at privacy@rapyd.net.

DPO, Questions, Concerns or Complaints: Rapyd has appointed PrivacyTeam Ltd. as its data protection officer for matters relating to privacy and data protection. If you have any comments or questions about this Policy or if you have any concerns regarding your Personal Data, please contact Rapyd’s appointed DPO by email by sending a message to dpo@rapyd.net.

Rapyd’s U.K. and Rapyd’s Iceland offices have been designated as Rapyd’s representatives in the United Kingdom (“UK”) and in the European Union, respectively. Our representatives may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please send an email to privacy@rapyd.net. If you are a GDPR- or UK-GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the UK or in the EU, as applicable.