In this policy we describe the types of information we may collect from you or that you may provide when you use our website and/or services (the “Platform”) and our practices for collecting, using, protecting, and disclosing that information.
This policy applies to information we, and not third parties, collect:
- On the Platform.
- In email, text, Slack, and other electronic messages between you and the Platform or Paysail team members.
- Through mobile and desktop resources you download from the Platform, which provide dedicated non-browser-based interaction between you and the Platform.
- When you interact with our advertising and Platform on third-party applications and services, if those services or advertising include links to this policy.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Paysail or any third party; or
- Any third party including through any application or content (including advertising) that may link to or be accessible from or on the Platform.
Children Under the Age of 13
The Platform is not intended for children under 13 years of age and you are not allowed to use the Platform or provide information on it if you are under 13 years of age. If we learn we have received personal information from or about a child under 13 without verification of parental consent, we will delete that information immediately. If you believe we might have any information from or about a child under 13, please contact us immediately at firstname.lastname@example.org or email@example.com.
If you are based in the European Economic Area (“EEA”) you may only use the Platform if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of the Platform has been provided to us.
Information We Collect And How We Collect It
We collect several types of information from and about users of the Platform, including:
- by which you may be personally identified, such as name and e-mail address (“personal information”);
- that is ascertained through our use of third-party applications, including but not limited to your user behavior and trends (such as your login and access times of the Magic platform);
- that you voluntarily enter, such as your name, your email address, your company’s name, your company’s business address, your company’s industry sector, your intended use of the Platform, your or your customer’s crypto details and your responses to survey and/or feedback questions;
- that is about you but individually does not identify you or your company;
- List information collected, including digital asset information if you sign up for a paid account;
- Additional information that you voluntarily enter, such as your company name, and your customer’s information related to invoices (such as currency, name, email address, company name, company business address, items listed on an invoice, memorandum information supplied by you on an invoice, and digital asset transaction information including block hash, block number, transaction hash, transaction id); and
- Information about your internet connection (such as your IP address), the equipment you use to access the Platform, and Platform usage details.
We collect this information:
- First, directly from you when you provide it to us, such as entering your information into an onboarding survey provided to you to access Paysail’s beta phase, signing up for an account, or adding your customer’s information on the Platform in order to create, send, receive, and/or pay invoices.
- Second, we collect generic information about your usage and equipment automatically as you navigate through the Platform, such as usage details, IP addresses, web browser preferences, and information collected through cookies and other tracking technologies. Although we do not correlate tracking information to individuals, some information collected, such as IP addresses, will be unique.
You also may provide information to be transmitted to other users of the Platform or third parties, such as through invoicing (“User Transactions”). Your User Transactions are transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to transmit your User Transactions. Therefore, we cannot and do not guarantee that your User Transactions will not be viewed by unauthorized persons. Company is not obligated to police, review or verify User Transactions in any way. Company is not liable for any User Transactions.
The information we collect is used by the Company to identify users and provide them with services, support, sales and marketing action, invoicing, and to meet contractual obligations.
Do Not Track Settings
The Company does not track its customers over time and across third party websites to provide targeted advertising, and therefore does not respond to Do Not Track (DNT) signals. However, some third party websites track your browsing activities when you use their websites so that they can tailor their content to your preferences. If you are visiting such sites, your web browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To develop, provide, and improve the Platform and its services to you.
- To provide you with information, products, or services that you request from us.
- To provide you with notices about your account and/or paid subscription, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to the Platform or any products or services we offer or provide though it.
- In any other way we may describe when you provide the information.
How We Store Your Information
Information that we collect about you or that you provide to us, including any personal information, may be stored through the following means:
- Cloud Firestore by Google Firebase database to store user information and invoicing details provided by Users about Users or User’s Customers (including but not limited to currency, customer name, email address and company name, information around invoice creation, due date, payment completion, number of invoice items, invoice item descriptions, invoice items amounts and quantities, invoice payment status, and transaction information).
- Celo blockchain to store payment information (including but not limited to invoice sender and recipient addresses, hash, and gas fees). More information on the Celo blockchain can be found here.
- Magic Link to store wallet address information, which is stored in a self-sovereign, non-custodial wallet (including public and private keys). More information on how Magic Link stores keys can be found here. Users may also access their wallet information (including their private key) at any time by submitting the email address associated with the User’s Paysail account through this link.
- By Paysail to store payment information (including but not limited to blockNumber, blockHash, transactionHash, and gas fee) and User’s public digital asset wallet address.
- Sentry to store event data including but not limited to User’s IP address, and information related to a User’s device and browser. However, this information is only stored by Sentry for ninety (90) days.
Sharing and Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Paysail’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Paysail about the Platform users is among the assets transferred.
- To fulfill the purpose for which you provide it. For example, if you give us your customer’s information in order to create and send an invoice to your customer through the Platform, we will transmit the contents of that invoice and the information you supply the recipient.
- For any other purpose disclosed by us when you provide the information.
- To third party contractors in order to analyze Platform performance and user behavior and/or to improve the Platform.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Paysail, our customers, or others.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to firstname.lastname@example.org or email@example.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a registration, product service experience, or other transactions.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Accessing and Correcting Your Information
You can review and change your personal information (with the exception of your name and business email address associated with your account) by logging into the Platform and visiting your account profile page. You may also send us an email at firstname.lastname@example.org or email@example.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Transferring your information
Paysail is a worldwide service. By using the Platform, you authorize us to transfer and store your information outside your home country, including in the United States, for the purposes described in this policy. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country. We take additional measures when information is transferred from the European Economic Area (EEA). This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access. For example, access by a user to its account and personal information secured by Magic’s password-less authentication.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.
You have options in relation to the information and data that we have about you. To exercise any of the options discussed below, please contact us at firstname.lastname@example.org or email@example.com. If you’re an EEA user, you may:
- Access the information we have about you. We'll will make an effort to share this information with you within a reasonable time.
- Have your information corrected or deleted.
- Object to us processing your information. You can ask us to stop using your information, including when we use your information to send you email communication.
- Withdraw your consent for us to collect and process your personal information at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- Have the information you provided to us sent to another organization, where we hold this information with your consent or for the performance of a contract with you, where it's technically feasible.
- Complain to a regulator. If you're based in the EEA and think that we haven't complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in Ireland or with your local supervisory authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Legal Basis for Processing Personal Information
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Third Party Links
The Platform may contain links that lead to other websites, and the Company is not responsible for the privacy practices, content, and/or activities of these linked websites. Nonetheless, we seek to protect the integrity of the Platform and welcome any feedback about these external websites.