Privacy Policy

Introduction

This Privacy Policy describes how we collect, use and share with third parties your personal data collected when you use and navigate the website of BuySellVouchers. We value our relationship with you and place the highest importance on respecting and protecting your privacy. We will only process your personal data in accordance with applicable law, including the General Data Protection Regulation (EU) 2016/679, and this Privacy Policy.

1. Terms

“BuySellVouchers“, “we“, “us“, and “our“ refer to ‘Overmorrow Trading Solutions OPC’ together with its employees, directors, successors, affiliates and assignees.

“You”, “customer”, “user”, “your” refer to users of the services of BuySellVouchers, whether in their capacity as senders, recipients, or visitors to our website.

Other terms used in this Privacy Policy shall be understood as they are defined in the applicable data protection laws.

2. Sending newsletters

We communicate with our customers about new products or services, special offers and other marketing announcements in newsletters sent by e-mail to our customers. Therefore, we process your first name, surname and e-mail address for direct marketing purposes.

The basis for the processing of your personal data for direct marketing purposes is your consent. Therefore, you have the right at any time to disagree with or reject such processing of your personal data for the purpose of sending newsletters.

BuySellVouchers may also send direct marketing communications to the customer providing relevant information about related BuySellVouchers services. The customer may at any time (in advance or at any time later) unsubscribe from such messages.

You can disagree with or reject processing of your personal data for the purpose of sending newsletters by clicking on the unsubscribe reference presented at the bottom of the newsletter sent to you or by notifying us in writing (for example, by e-mail or via support channel https://www.buysellvouchers.com/en/support/index/).

Your personal data, which we process for the purposes of direct marketing, shall be stored for a term of 3 years from the date of your consent unless you revoke your consent before the expiry of the said term. After the expiry of the said term or in the event you revoke your consent, we will cease the processing of these personal data for the purpose of direct marketing.

3. Visiting the website

When you browse our web page without logging in, we do not hold any personal data about you, but we use various tools to help us maintain the website and provide the best possible experience for you.

Each time you access or visit the website, the following technical personal data may be automatically collected: IP address, access date and time, web page name and URL, device operating system data, information about the Internet provider, geo-location data, language settings and other relevant data.

BuySellVouchers is not responsible for the protection of the Client's privacy on websites of third parties, even if such websites are accessed by the client through links provided on this website. We recommend to learn the privacy policies of each website that does not belong to BuySellVouchers.

4. Cookies

We use cookies and similar technologies as described in this Section. By consenting to this cookie notice, you agree that we can distinguish you from other users of our website and apps for the purposes set out below. This helps provide you with the services you have requested, good user experience, tailored content and interest-based adverts. For example, we can recognize and remember important information, such as preferred settings, that will make it more comfortable for you to browse our website.

What are Cookies and similar technologies?

A cookie is a small file of letters and numbers that we store via your browser on the hard drive of your computer or mobile device.

There are three main types of cookies:

• Session cookies: specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don't have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;
• Persistent cookies: record information about your preferences and are stored in your browser cache or mobile; and
• Third party cookies: placed by someone other than us which may gather data across multiple websites or sessions.

We may also automatically collect and store certain information about your interaction with our Website or app including, but not limited to IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps and related data.

Other technologies

In addition to cookies, we may use some other similar technologies as follows:

• Web Beacons: small graphic images included on our website or emails or those of third parties to provide analytics information
• Social widgets: buttons or icons provided by third party social media networks which may collect browsing data and will be received by the third party and are controlled by the third party
• SDKs: these are mobile application third party software development kits used in our apps. They enable us to collect information about app activity and the device it runs on.
• Local shared objects: these are sometimes called flash cookies and can be stored on your browser. They are used to maintain preferences and usage records.

Cookies we use

Third party cookies

You acknowledge that where we allow the third parties identified above to drop cookies, we have no control over those cookies or the data generated. Please refer to the third party's privacy policy for information on what information they collect and how they use it.

Refusing or deleting cookies

Please click on the following links to adjust your browser settings:

• Internet Explorer
• Google Chrome
• Mozilla
• Firefox
• Safari

Please note that you may not be able to take advantage of all features of our Website or apps if you delete or refuse cookies.

Mobile Opt-out

If you access our services through our Apps, you can enable a "do not track" feature so as to control interest-based advertising on an iOS or Android mobile device by selecting the Limit Add Tracking option in the privacy section of your Settings on iOS or via advertising preferences on Android devices (e.g. in Google Settings). This will not prevent the display of advertisements but will mean that they will no longer be personalized to your interests.

To opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

For more information on managing cookies, please go to www.allaboutcookies.org.

If you are a resident in the EU:

For more information on managing cookies, please visit www.youronlinechoices.eu which has further information about behavioral advertising and online privacy.

5. Provision of the services

For regular business operations, conclusion and fulfillment of our agreements with you on use of respective BuySellVouchers services as well as implementation of the requirements established in the legal acts regulating the operations of a payment institution we collect and process your personal data.

Such personal data may be provided to us by you directly when creating an account on BuySellVouchers website or collected from other financial institutions or the other third parties (included, but not limited to Facebook, Gmail, Vkontakte, Paysera, etc.) if you choose to create an account on our website using already existing your social networking or other accounts mentioned here above.

We may process the following personal data of the customers:

• personal data (first name, surname, occupation, company represented and position held, data about the citizenship, personal ID number, etc.);
• contact details (residential address, e-mail address, telephone number, etc.);
• financial data (bank (electronic money payment institution) account information, etc.);
• other data provided when creating an account on BuySellVouchers website and / or required for the provision of the respective BuySellVouchers services.

The basis for the processing of your personal data is agreement which shall be or is entered into by BuySellVouchers and the customer. In any case we process the personal data of our customers only to such an extent which is necessary for ensuring the proper provision of e-currency top-up and withdrawal services and implementation of the legal obligations binding BuySellVouchers.

Customers also have the possibility of logging into their individual accounts on the website of BuySellVouchers, where any information that is relevant to the respective customer in connection with the particular service is provided. Customers log into their accounts using the unique login data provided to them. With a view to properly administer this system, BuySellVouchers also processes additional personal data of customers, inter alia: customer user IDs, login passwords, time of the customer’s login to his / her individual account, data provided in the customer’s applications or agreements, data on transactions carried out by the customer as well as other data. BuySellVouchers processes such personal data under the agreements concluded with customers.

Personal data collected for the purpose of conclusion and fulfillment of agreements will be stored for up to 8 years from the completion of the transaction, the submission of the respective application or execution of the operation except for the cases when the legal acts provide for a longer term of storage of such data.

6. Prevention of money laundering and terrorist financing

As a company and obligated entity, we are required to reliably identify the customer, the representative or the beneficiary before providing any service and do everything in our power to prevent any money laundering and fraudulent activities. For this we may need additional information and / or documentation from the customer, depending on specific cases.

Personal and financial data required to comply with international know your customer, anti-money laundering and combating the financing of terrorism requirements and perform financial and business operations include:

• personal data (first name, surname, nationality, date of birth, personal ID number, etc.);
• contact details (residential address, e-mail address, telephone number, etc.);
• financial data (bank (electronic money payment institution) account information, transaction history, etc.);
• other personal data which may help us comply with the applicable law and prevent fraudulent behavior.

The personal data which are required under the law, are usually provided to us directly by you. We shall also have the right to establish the identity of the customer, the representative or the beneficiary without their direct involvement by receiving the required information in accordance with the procedure laid down in the law from other financial institutions and authorized entities (when it’s applicable). By properly implementing the requirements for the prevention of money laundering and terrorist financing, BuySellVouchers can obtain additional personal data on customers, their representatives and beneficiaries from other third parties (for example, customer’s data can be verified in the databases on wanted persons and in international commercial and open source databases which accumulate and store information about the persons involved in politics, etc.).

We store your personal data in compliance with the requirements of the law, i.e. for a term of 8 years from the date of completion of transactions or expiry of business relations with the customer (unless other legal acts provide for a longer time limit for the storage of data). Certain personal data shall be stored for a shorter period of time, (for example 5 years), when it is laid down by the law.

7. Submitting requests

To ensure timely and appropriate processing of your requests, contact you regarding any information you provide, protect customers’ and / or our interests and fulfill various legal requirements, we process your personal data when you contact us (by e-mail, through our website, social media accounts or by any other method). We keep all communications with our customers to ensure that in case of disputes we have all available communication logs.

The basis for the processing of your personal data upon your request is consent which is expressed through your active actions – submitting a request.

We store your personal data for the above mentioned purposes for up to 3 years, depending on the nature of received personal data and other circumstances. We apply longer periods of personal data storage when there is a reasonable suspicion of an unlawful act which is subject to investigation; your data is necessary for the proper resolution of the dispute, complaint or claim; we have received complaints related to you, or if we have noticed any violations committed by you; it is necessary for back-up copies or related purposes of functioning of our information systems; it is mandatory required by applicable laws.

We kindly recommend to protect your personal data when submitting the requests and therefore do not disclose certain personal data if such disclosure is not necessary for development of your request.

8. Data transmission to third parties

We use services provided by third parties (such as third-party data centers, servers, website design, administration services, online traffic and website analysis, statistics, direct marketing services, payment services, etc.) that may require access to your personal data to the appropriate extent. We take data protection seriously and always partner only with companies which provide Data Processing Agreement (DPA) or other data protection agreements with these companies.

We may also share your personal data with any member of our group or subsidiaries (i.e. any organization we own or control) or our holding company or ultimate holding company (i.e. any organization that owns or controls us) and any subsidiaries they own. These companies will only use your personal information to provide a service to us or to you in the same way as we can under this Privacy Policy.

In the event that we sell any business or assets, personal information may be disclosed or transferred to buyers or prospective buyers of our business or any of our assets as part of any such sale.

Particular technical data pertaining to your visits to the website (such as IP address, data collected or placed on devices by cookies, technical information of the browser, other information related to your browsing activities, etc.) may be transferred or made available to entities in the European Economic Area (EEA) as well as outside the EEA for purposes related to statistics, analysis and other related lawful purposes. Please note that personal data in non-EU countries maybe subject to less protection than in the EU. We will carefully assess the conditions under which such data will be processed and stored after transfer to the above entities.

Finally, your personal data may be submitted to law enforcement, judicial or pre-trial institutions without any specific consent for the purpose of investigation or when it is mandatory by law.

9. Security of your data

We take protecting of your data very seriously – we encrypt the information you provide during the transmission of the information, our internal systems are logging access to your data when / if accessed by our employees, our offices have perimeter control from unauthorized entry, we have internal IT security procedures and use best security practices to minimize risks from outside attacks, all critical systems require 2 factor authentication and / or are accessible only through internal network / VPN.

While we implement security measures on our website and through our services, you should be aware that 100% security is not always possible. Whenever you give out personal information online there is a risk that a third party may intercept and use that information. While we strive to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. By using BuySellVouchers services, you expressly acknowledge and agree that we cannot guarantee the security of any data provided to or received by us through the services and that any personal information, general information, or other data or information received from you through the website or our services is provided at your own risk.

10. Your rights

General Data Protection Regulation (EU) 2016/679 gives you more rights to control which data about you can be accessed by companies like us. Here is a list of rights specified in regulation:

• The right of access to your personal data. You have the right to receive confirmation that we process your personal data as well as the right to access your personal data processed and information about the purposes of processing, the categories of data being processed, the categories of data recipients, the period of data processing and the sources of data;
• The right to rectification. If you think that data processed by us is inaccurate or incorrect, you have the right to request that such data be modified, clarified or corrected;
• The right to erasure (right to be forgotten). When there are circumstances specified in certain legal acts, you have the right to request us to erase your personal data;
• The right to a restriction of processing. When there are circumstances specified in certain legal acts, you also have the right to request us to restrict the processing of your data;
• The right to data portability. You have the right to transfer your data processed by us with your consent and by automated means to another data controller;
• The right to disagree with the processing of your personal data if it is processed on a legitimate interest basis, unless there are legitimate reasons for such processing or for the purpose of claiming, enforcing or defending legal requirements;
• The right to revoke your consent to process your personal data. If we have no other legal basis for the processing of personal data, we will cease processing of personal data immediately after the cancellation / revocation of the consent provided by you;
• The right to file a complaint to the State Data Protection Inspectorate. However, we kindly recommend you to contact us first in order to find a satisfying solution.

11. Additional information

BuySellVouchers is not intended for users under the age of 18. Such users are expressly prohibited from submitting their personally identifiable information to us and from using portions of the website of BuySellVouchers for which registration is required; any information submitted by such users will not knowingly be used, posted, or retained.

We reserve the right to amend this Privacy Policy. The amended Privacy Policy shall be published on our website, so we kindly recommend to check our website periodically if there are any amendments of the Privacy Policy.

If you have any questions about this Privacy Policy, please contact-us.