Legal Documentation

1 Basic information

1.1 About the company

The service is provided by VLPAY LLC. The conditions applicable to each operation are shown before confirmation.

For more information about the VeltroPay Group, see our Terms and Conditions.

1.2 About the Privacy Policy

This Privacy Policy regulates the processing of personal data provided by the User through the www.veltropay.es website (hereinafter referred to as the ”Website”) that is made available to Internet users.

This Policy is an integral part of the General Conditions and will be accessible at all times from the Website.

If we change the way we treat your personal data, we will update this policy. We reserve the right to make changes in our practices and to update this policy (or any policy) accordingly at any time, so we encourage you to check frequently for updates or changes.

1.3 About the controller and the processor of your personal data

The controller of your personal data is VLPAY LLC, in accordance with Article 26 et seq. of the European Data Protection Regulation.

Details of the data controllers:

If you have any questions or concerns about the data or your rights, you can send us an email to Info@veltropay.es and we’ll make sure your enquiry gets to the right department.

2 What Personal Data do we Use?

Personal data, or personal information, means any information about an identified or identifiable natural person.

In accordance with the existing personal data protection legislation, the personal data and information provided by the website user (hereinafter referred to as the ”User”) when completing any electronic form available on the website will be included in a database owned by VLPAY LLC.

In order to make use of our services, it is essential for the User to provide a series of personal data. The data we collect about the User during the registration process - in order to create a User profile on the Website - are:

• Personal data: name and surname, identity document (date of issue, issuing authority, identification number and expiry date), nationality, postal address and country of residence, date of birth, sex and actual image or photograph.
• Contact details: e-mail address, postal address and telephone number.
• Other personal data: profession, relationship with the beneficiary, etc.

To make use of our specific Services, and depending on the service contracted, we will request and process additional personal data (bank data, means of payment used, last digits of your credit card, financial institution, personal data of the transaction beneficiary, bank data of the beneficiary, etc.). Please note that the type of data requested may vary according to the type of service contracted, the country from which you intend to contract the Service, the country you intend to send money to, etc.

In all cases, in order to respect the principle of data minimization, only those strictly necessary to ensure the proper provision of the service will be requested.

In accordance with our obligations to prevent money-laundering, we must inform you that, in certain circumstances, we may be obliged to request additional information and documentation from our Users (for example, proof of postal address, proof of the source of funds, bank account statements, etc.). Precisely what is required will depend on the characteristics of the specific transaction.

The data included in each of the forms are voluntary, except for those that are mandatory (indicated as mandatory). Please note that, if these mandatory data are not provided, it will not be possible to process the User’s request or provide the required service. The User declares under their own responsibility that the data provided to VeltroPay are true, correct and belong to them. Any false or inaccurate statement made as a result of the information and data provided, as well as any harm that such information may cause, will be the responsibility of the User. Users who provide false data may be excluded from the services of the website.

2.1 Information we collect about you:

Server data: To provide the service, your Internet browser transmits various forms of data to us through third-party providers (so-called server log files). These data files that are recorded include:

• Browser plug-ins and language
• Date and time of access
• Your Internet Protocol (IP) address
• Details of the transactions you make when using our Services, including the geographical location from which the transaction originates.

These data are anonymous and are stored separately from the personal data you have provided us. It is not possible to draw conclusions about a particular person. Data are analysed for statistical purposes to optimize our website and our offers.

3 What is the Lawfulness and Purpose of Processing?

3.1 Lawfulness of processing

We’ll only use your personal data when the law allows us to.

The lawful basis on which we process your personal data is:

• To fulfil the contractual obligations arising from the contract with the User.
• Where the User has given his or her express consent, where necessary.
• Where processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not prevail over those interests.
• Where the processing is necessary to meet the legal and regulatory obligations to which we are subject.
• When processing is necessary to protect the vital interests of the user, ourselves or any other natural person.

3.2 Purpose of processing

The purpose of processing such personal data is to create a User profile owned by the specific customer on the Website so that you can make use of our Services, as well as to process the User’s request properly and on time.

The requested data and the specific processing of the data will vary depending on the service requested by the user. Depending on the nature of the service contracted, the purpose of the processing will be to send the money requested, to recharge a mobile device, and in general to provide the services expressly contracted by the customer through the Website.

In addition, the personal and contact data of the users are necessary for the customer service, including the response to queries or complaints. This may require the use of certain information related to the reason for the consultation (such as the status of a transaction, a technical issue, a question or complaint about a product, or general questions, etc.). The information provided by the user will be stored in order to process the request. The data will not be transmitted to third parties. The data thus collected will not be compared to the data that may be collected by other components of our website.

Your contact details will also be used to provide you with relevant additional information and content through our newsletter, provided that you have expressly subscribed to it. To receive our newsletter, you need a valid e-mail address. We will check the e-mail address you have entered to ensure that you are indeed the holder of the email address provided or that the holder is authorized to receive the newsletter. When you register to receive our newsletter, we will save your IP address and the date and time of your registration. The data so collected are used in our content creation software in order to create, distribute and analyse the effectiveness of our newsletter. They are not transmitted to third parties. Nor are the data collected in this way compared with data that may be collected by other components of our website. You can unsubscribe from this newsletter at any time. You will find details in the confirmation email and in each individual newsletter.

They will also ultimately be processed to improve the use of the website.

Finally, we need to process your personal data, in accordance with our own and your legitimate interests, to protect our Customers and the Company from any attempt at fraudulent actions against the platform, the Users and / or our Company.

4 Disclosure of your Personal Data

We share your personal data with the following types of third-party organisations:

Service providers. These are external companies that we use to help us carry out our activity (such as KYC providers, payment processing, fraud detection and identity verification, website operations, etc.). Service providers and their selected staff can only access your personal data and use them on our behalf for the specific tasks they have been asked to do, following our instructions. They are required to protect your personal data and to use them only for the specific service required. Where permitted by applicable law, you may request from us a list of the providers that process your personal data.

Competent authorities. Public bodies or supervisors where the applicable legislation so requires.

We can also collect personal information to meet applicable legal obligations, for example:

• To meet legal obligations if regulatory authorities and public bodies request more information about our company, our services or even specific operations.
• In support of the fight against fraud, crime or other defensive measures of public authorities, but also of financial institutions, etc.
• In case of a court order.
• In the event of a total or partial acquisition of the undertaking or its assets.
• In the financial or commercial risk assessment, data can be transmitted to special suppliers.
• Settlement of debts

5 How long will we keep your Personal Data?

We will keep your personal data for the period necessary to ensure the proper provision of the contracted service.

After that period, the data shall be anonymized, in accordance with the provisions of the data protection rules and the other applicable rules, which implies their blocking, and shall be available only at the request of the competent judges and courts, the Prosecutor’s Office or the public authorities during the limitation period of the actions which may arise from them for their subsequent elimination.

In general, the personal data provided shall be kept for the minimum time necessary to meet the user’s request and to meet the requirements of the relevant regulatory authorities.

6 Rights of Users

The rights of all our users, their successors, representatives and / or agents in the field of data protection are those legally provided for and conferred by the data protection rules. In particular:

• Right of access: you have the right to know what type of data we are dealing with and the characteristics of the processing we are carrying out.
• Right of rectification: you may request the modification of your data if they are inaccurate or false.
• Right of portability: you can obtain a copy in an interoperable format of the data being processed.
• Right of restriction: You have the right to restrict the processing of your data in the cases provided for by law.
• Right to erasure: you may request the deletion of your data when it is no longer necessary to process or retain them.
• Right to object: you may request the cessation of commercial communications in the terms indicated above.
• Right to revoke consent: provided that no requests have been made; where requests have been made, the data shall be kept in accordance with the established regulatory requirements.

At any time, users who have provided personal data to VeltroPay through the Website may exercise their rights with regard to the processing of their personal data by sending a written and signed request to the address Info@veltropay.es or by post to the address indicated in the heading of this document. The request must indicate the name and surname of the User, address for the purposes of notification, photocopy of the National Identity Document or passport and indication of the right to be exercised.

Also, at any time, the User may oppose the use of his personal data for commercial purposes by sending an e-mail to Info@veltropay.es.

Please note that any information provided to us will only be processed in accordance with the applicable legislation and to the extent that it allows.

In addition, keep in mind that, in certain circumstances, we may not be able to remove your personal data without also removing your user account. We may need to keep some of your personal data after you have requested its removal to meet our regulatory and legal obligations.

We will be happy to answer any questions you may have about how we process your personal data. However, if you have any problems to solve or are not satisfied with the solution or response we have given you, you can exercise your right to file a complaint with the competent data protection authorities in your country.

7 International Data Transfers

The storage and processing of your personal data as described above may require that they be transferred to and/or stored at a destination outside your country of residence, in particular Germany and France, where they are stored.

We will also transfer them to countries outside the European Economic Area (”EEA”) (such as to other subsidiaries of the VeltroPay Group, which include countries that have data protection standards other than those applicable in the EEA). We (i) have established standard contractual clauses approved by the European Commission to protect your personal data (and you are entitled to request a copy of these clauses by contacting us as follows) and / or (ii) will rely on your consent when permitted by law.

8 Security measures

VeltroPay has adopted the legally required security levels for the protection of personal data, installing the means and technical measures available to it to avoid loss, misuse, alteration, unauthorized access and theft of the personal data provided. However, the User must be aware that the security measures on the Internet are not impregnable.

Your personal data will be processed by our staff or agents authorized to obtain certain information in accordance with the specific purposes for which they were collected.

We store your personal data in operating environments that use reasonable security measures to prevent unauthorized access. We follow reasonable rules to protect personal data. Unfortunately, the transmission of information over the Internet is not completely secure. Although we do everything we can to protect your personal information, we cannot guarantee data security during its transmission through our websites / applications.

To help maintain data security, there are certain self-protection measures that we expect all our Users to take. It is important that you also do your part to ensure the security of your personal data. When you register on the Website and create an account, make sure you choose a password that is difficult to guess and never provide it to anyone. You are responsible for your confidentiality and the exclusive use of your account. If you use a public or shared computer, do not ever choose to remember your user name / email address or password. Be sure to log out every time you leave the computer. You must also use the privacy settings or controls we offer on our website.

9 Cookies

In compliance with Article 22 of Law 34/2002 of 11 July on information society services and electronic commerce (hereinafter ”LSSI”), VeltroPay may use data storage and retrieval devices (hereinafter ”Cookies”) in the terminal equipment of the recipients, provided that they have given their consent after receiving clear and complete information on their use. The User may obtain complete information on the purpose of the installation of Cookies and the uses to be given to them in the VeltroPay Cookies Policy.

This shall not prevent the possible storage or access of a technical nature only for the purpose of transmission of a communication by an electronic communications network or, to the extent strictly necessary, for the provision of an information society service expressly requested by the addressee.

10 Amendments

Any User who accesses the Website is obliged to be aware of VeltroPay’s Privacy Policy and to consult it regularly, as it may be subject to changes by VeltroPay without prior notice.

The Company’s Official Languages are English and Spanish. Any version of the Privacy Policy in languages other than English or Spanish is offered for the purpose of being more transparent with our Users and for the sole purpose of reaching all the markets in which we offer services.

However, in the event of a discrepancy between this language version and the English and Spanish versions, the provisions contained in the latter shall prevail.