Privacy Policy

If you are visiting the Website, intend to use the Services, or are already using them, please read this Policy carefully. If you disagree in any way with the terms set out in this document, please refrain from visiting the Website and/or using the Services.

The fact of your visiting the Website and/or using the Services confirms that you have read and fully accept the terms of this Policy, and that you have given consent to the collection and processing of your Personal Data.

The terms of the Policy may be changed at any time without personal notice to each User by publishing a new version of the Policy on the Website, indicating the time it takes effect. Your continued use of the Website and/or Services after the new version of the Policy takes effect indicates your full acceptance of the new terms.

1. Terms

Account — a personal user record of the User on the Website that allows the User to provide and change their registration data, including Personal Data, generate payment templates, participate in promotions, receive individual offers, and use other functional features of the Website.

Device Information — data that may be automatically collected from any device used to access the Website or Services. Such information may include, among other things, connection type, the name and IP address of your device, information about the web browser and internet connection you use to access the Website or Services, Location Data, information about applications installed on the device, and biometric data.

Location Data — information that indicates your location with reasonable accuracy, using, for example, longitude and latitude coordinates obtained via GPS, Wi-Fi, or triangulation using cellular network nodes.

Personal Data — data or a set of data about an individual who is identified or can be specifically identified. Personal Data may include surname, first name, patronymic, date-of-birth information, mailing address (including billing and delivery addresses), phone number, email address, payment instrument information, other account details, account number, and details of identity documents (e.g., driver's license, passport, etc.).

Services — payment services, data processing services, any other services, goods, content, features, technologies, or functions, as well as all related websites, programs, and services offered to you by iPay.

Websites — websites, mobile applications, official social media platforms, and other online venues used by iPay to offer its Services or that contain a reference to this Privacy Policy.

Technical Usage Data — information we collect from your phone, computer, or other device that you use to access the Websites or Services. Technical Usage Data shows how you use the Websites and Services. This may include data on what you searched for and viewed on the Websites, and how you used the Services, including your IP address, statistical data on page loads and views, websites visited before arriving at the Website, and other information regarding usage and browsing collected via cookies.

User — an individual who uses the Services or visits the Websites.

2. General Information

This Privacy Policy applies to your Personal Data while you visit the Website or use the Services, and does not apply to websites or services that are not owned by or controlled by iPay, including websites or services of other persons.

Please note that this Policy does not apply to sites accessed via links placed on the Website, or to persons who provide the User with related services connected to the Services. When following links placed on the Website, we recommend reviewing the privacy and personal data protection policy of each respective site.

By visiting the Website or using the Services, you hereby grant iPay and third parties that carry out identification, simplified identification, or verification procedures and services, permission to perform operations with your personal data in accordance with this Privacy Policy, namely processing (collection, recording, systematization, accumulation, storage, verification (updating, changing), retrieval, use, transfer (including dissemination, disclosure, provision, access), depersonalization, blocking of access, deletion, or destruction).

By visiting the Website or using the Services, you confirm that you have received notice of the possible transfer of your Personal Data in the manner provided for by this Privacy Policy, and you grant us permission for such transfer.

3. Types of Information Collected When Visiting the Website and When Receiving Services

We collect and store your Personal Data while you visit our Websites or receive our Services, including the information listed below.

• Registration and usage information.

When you register to receive our Services and create an Account or a billing account, we collect the Personal Data necessary to offer and provide the Services you requested. Depending on the Service you select, creating an Account or billing account may require the following information (the list is not exhaustive): surname, first name, patronymic, mailing address, contact phone number and email address; tax number (identification number); identity-verification data; login and password; information about an electronic payment instrument and/or payment details; data that allow requesting invoices from goods/works/services providers; other information (payment behavior and preferences, language, age, date of birth, gender, and marital status). We may require you to provide additional Personal Data when using some of our Services.

We do not collect any information whose processing is subject to specific legal requirements, such as information about racial or ethnic origin, political, religious, or ideological beliefs, membership in political parties or professional unions, criminal convictions or sentencing to criminal punishment, as well as data relating to health, sexual life, or biometric or genetic data (in accordance with Article 7 of the Law of Ukraine "On Personal Data Protection").

Information referred to in the preceding paragraph may only be processed by us if voluntarily provided by you when receiving the Services and in the case that you have given unambiguous separate consent for its processing for one or more specific processing purposes.

To access certain Services, registration is required — creating your own personal user record on the Website (Account). A User may register independently, only by agreeing to the terms of this Privacy Policy. Users bear personal responsibility for all actions taken during the creation and use of the Account. We strongly recommend not disclosing your Account login/password to third parties and not using it on other web resources. If you become aware that your login/password has been compromised, or of unauthorized actions involving your Account, please notify iPay immediately.

• Transaction and service information.

When you use our Services or visit our Website (for example, to make purchases, pay bills, process payments, or transfer funds), send messages to mailboxes or by other means, we collect transaction-related information, as well as other data related to the transaction, such as the amount sent or requested, the amount paid for goods or services, information about the seller, including information about any financial instruments used to carry out the transaction, Device Information, Technical Usage Data, and Location Data.

Since iPay processes transactions using electronic payment instruments and provides related services, iPay may receive limited Personal Data of Users from other participants and members of payment systems, financial institutions, banks, and other institutions involved in such transactions, as well as from other public sources.

• Information about participants.

When you use our Services or visit our Website, we collect Personal Data that you provide to us about other participants related to the transaction.

• Transfer or request of funds.

When you make or request a transfer of funds using the Services, we collect Personal Data such as full name, mailing address, phone number, and account details of the transfer participant who receives funds from you or sends funds to you. The scope of such Personal Data may vary depending on the Services you use for the transfer or request of funds.

• Account top-up.

If you use our Services to top up your bank account or any other account you may have, or if you ask a User to top up any such account, in order to fulfill the request we may collect Personal Data of another person received from you, or your Personal Data received from another person. For example, if you use our Services to top up your mobile account or arrange for a top-up of your mobile account, we may collect Personal Data and other information received from another participant, including the mobile account number.

• Your Personal Data obtained from third-party sources.

Where permitted by law, we collect data from third-party sources such as merchants, companies that support digital wallets (GooglePay, ApplePay, PayPal, etc.), data providers, and credit bureaus.

• Other information about your use of our Website and Services.

We may collect additional information obtained from you or from other sources when you contact us, reach out to our customer support teams, or take part in surveys or promotions.

We collect Website visit statistics. This data may include information about connections, traffic, the User's browser, as well as the date, duration of internet activity, and presence on the Website. Such information may have the characteristics of Personal Data if it allows identifying you as a specific individual.

• Information obtained by us as a result of recording your telephone conversations with iPay customer support regarding the use of the Website and Services.

Information obtained in this manner, including Personal Data, may be used solely for the purpose of assessing service quality, statistics, and improving service quality, as well as for resolving disciplinary and other matters concerning employees of the Administrator and third parties engaged in providing the Services.

4. Legal Grounds for the Use of Personal Data

In accordance with the requirements of current Ukrainian legislation on personal data protection, we process your personal data on the following grounds:

• Performance of a contract: processing of your personal data necessary to fulfill our contractual obligations;
• Legal obligation: we are required to process your personal data in order to fulfill a statutory obligation, for example, keeping records to provide information to a particular government authority;
• Legitimate interests: we will process information about you when such processing falls within the scope of our legitimate interests in conducting lawful business activity and is necessary for continuing that activity, provided such processing does not infringe your interests;
• Your consent: processing of your personal data is carried out only with your consent obtained. You have the right to withdraw your consent at any time.

5. Personal Data Retention Period

We store Personal Data in a format that allows identification of the person for the minimum period of time necessary to fulfill our legal obligations or requirements of regulatory acts, as well as to achieve our business goals. We may retain Personal Data for a period exceeding the statutory term if such retention is consistent with our legitimate business interests and is not prohibited by law. If your Account is closed, we may take measures to delete (destroy) or anonymize (depersonalize) Personal Data and other information, but we reserve the right to store and use data for as long as necessary to comply with legal requirements. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

Cookies we use may have a certain validity period, and if you do not visit our Websites or use our Services during that period, these cookies are automatically deactivated and the collected data is deleted.

6. Purposes of Processing Personal Data

We may process your Personal Data for various purposes permitted by Ukrainian legislation on personal data protection.

• Managing the operation of the Website and providing the Services, including:
  • executing payments, transferring or requesting funds, paying an issued invoice;
  • verifying identity to grant access to the Account;
  • interacting with you on matters related to your Account, the Website, the Services, or the company iPay;
  • updating your Account data and your financial information.
• Solving business tasks, such as monitoring, analyzing, and improving Services, as well as increasing the productivity and functionality of the Website. For example, we analyze user behavior and study how you use our Services and Website.
• Managing risk and protecting the Website, Services, and you from fraud through verification of your identity; iPay uses Personal Data, Device Information, Technical Usage Data, and Location Data from the Website and websites offering iPay Services to detect and prevent fraud and unlawful use of the Services.
• Fulfilling our obligations and ensuring compliance with the terms of use of the Website and Services, including ensuring compliance with current Ukrainian legislation.
• Satisfying our legitimate interests, in particular:
  • ensuring compliance with the terms of use of our Website and terms of providing Services;
  • solving day-to-day business tasks such as monitoring and analysis;
  • managing risk, preventing fraud and unlawful use of the Website and our Services;
  • depersonalizing Personal Data to provide third parties (including other companies and members of the public) with aggregated statistical data about how, when, and why Users visit the Website and use our Services;
  • providing personalized Services (contextual advertising services) offered by iPay on third-party websites and online services. We may use your Personal Data and other information collected under this Privacy Policy to provide you with targeted content, features, or offers on third-party websites.
• Achieving the following purposes with your consent:
  • using cookies and other tracking technologies to provide you with targeted content, features, Services, or offers, and/or to work with other third parties, such as merchants, advertising, or analytics companies, for the purpose of providing such personalized services (contextual advertising)
  • responding to your requests, for example, requests to contact you regarding a question you raised with customer support;
  • sending you personalized Promotions, marketing activities, and surveys. When using User data for direct marketing (commercial mailing and marketing messages about new services and offers that may be of interest to Users), a link is included that allows the User to opt out of receiving such messages in the future.

7. Categories of Recipients of Personal Data

Information received from you is intended solely for iPay employees and persons engaged by iPay for the purpose of providing the Services. Disclosure of information to third parties will only take place within the scope and for the purposes provided for by this Policy.

We may provide your Personal Data and other information about you to other persons in various ways, as described in this section of the Privacy Policy. We may provide your Personal Data and other information to the following persons in the following cases.

• Third parties involved in servicing the Website or providing the Services. We may provide your Personal Data to third parties involved in servicing the Website and providing the Services, including for the following purposes: providing the Services you requested or approved, risk management, detecting and preventing potentially unlawful or fraudulent actions and other violations of our policies and rules, managing the availability of products, Services, and iPay's communication channels and the ability to connect to them.
• Other companies that provide services to us. We transfer Personal Data to third-party service providers who provide services and functionality at our direction and on our behalf. Such independent service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertising messages about our products and services, or provide customer support services.
• Other financial institutions. We provide Personal Data to other financial institutions with whom we jointly create and offer certain products. Such financial institutions may use this information only to promote and offer products related to iPay, unless you give permission for other types of use.
• Other participants in transactions when you use the Services (e.g., other Users, merchants, and their service providers). We may provide information about you to other persons involved in processing your transactions, including other Users to whom you send a transfer or from whom you receive one, as well as merchants and their service providers.
• Other third parties to achieve our business goals or as permitted or required by law. We may transfer information about you to other persons to achieve iPay's commercial goals, or in cases where such transfer is permitted or required by law, including if:
  • we are obligated to do so in accordance with legal requirements, a court decision, or requirements of law enforcement or regulatory authorities;
  • we determine at our own discretion that disclosure of Personal Data is necessary to prevent harm to health, protect a person's vital interests, or protect against financial loss, and in connection with the investigation of unlawful activity or events bearing signs of fraud;
  • information is transferred to credit agencies and data processors to verify creditworthiness and combat fraud;
  • this is necessary to investigate violations or ensure compliance with an agreement with a user or rules applicable to use of the Website or provision of Services;
  • Personal Data is transferred to partner banks and other members of card associations in accordance with their "blacklist" inclusion rules;
  • disclosure of Personal Data is necessary to conduct an audit, ensure compliance with current legislation, and support corporate governance functions.

8. Information Regarding the Use of Cookies and Tracking Technologies

Cookies are a small amount of data sent by the Website and stored by your computer's browser. When you use our Services, visit our Website, or a third-party website for which we provide internet services, we, as well as our business partners and providers, may use cookies and other tracking technologies (collectively referred to as "Cookies") to recognize you as a User and personalize online service during use of the Services, other online content and advertising, evaluate and analyze the effectiveness of advertising campaigns, reduce risk levels, prevent possible fraud, ensure the security of our Website and Services, and build an atmosphere of trust. In addition, iPay uses standard web-server logs to count the number of visitors and assess the technical capabilities of our Website. This information is used to organize the Website in the most convenient way for users, to ensure the Website's compatibility with browsers used, and to make the content of the Website's pages as useful as possible.

iPay collects certain information during your interaction with our advertising and mobile applications. The information we collect in this way may include IP addresses, browser type, operating system, the URL of the referring source, and information about actions taken or interactions with our digital solutions. iPay may also use Internet tags (a clear GIF file) to return information to the web server.

Some aspects and features of our Services and Website are only available with the use of cookies, and your decision to disable cookies or opt out of them may limit your ability to use the Website and Services, or deprive you of the ability to use them.

9. Rights of Users as Data Subjects

Subject to the restrictions established by Ukrainian data protection legislation, you have certain rights regarding your Personal Data. In particular, you have the rights to access, rectification, restriction, erasure, and data portability. Contact us if you wish to exercise these rights. If you request access to all of your Personal Data held by iPay, you will need to provide a document with a photograph to confirm your identity.

Generally, if you have an Account for any of our Services, you can view and edit Personal Data. To do this, log in and update the information yourself. iPay may use an automatic transfer initiation mechanism, or if permitted by Ukrainian law, at your request.

Please send us a request if you need additional information about automatic transfer initiation.

In accordance with applicable law, a User has the right to withdraw any consent previously given to us, or at any time, on lawful grounds, to object to the processing of their Personal Data. We will take such a decision into account for all further actions. In some cases, this will result in the inability to use certain iPay Services.

A User, in accordance with applicable law, may have the right to: obtain confirmation that we store their Personal Data, request access to such data and receive information about what data we store, obtain copies of the Personal Data we store, make changes and additions and correct inaccuracies in Personal Data, object to processing, and demand blocking, anonymization, or, accordingly, deletion of all or part of the data.

If you have a complaint regarding the processing of your Personal Data, you may submit it to iPay, to the Ukrainian Parliament Commissioner for Human Rights, or to a court.

10. Personal Data Protection Conditions

All necessary measures are taken to protect your Personal Data from unauthorized access, alteration, disclosure, or destruction using appropriate technical and organizational tools.

You are responsible for ensuring that the password used to access the Account is not accessible to third parties. We will not ask you for your password (except when you log in to the Account on the Website).

11. Contacts

You may contact us if you have general questions regarding this Privacy Policy, additional notices, or the procedure for processing your Personal Data, by email at help@ipay.ua or by letter to iPay's office address in Ukraine: 45a Nizhnyourkivska St., Kyiv, "Universal Payment Solutions" LLC.

To help us prepare a response to your request, please provide full information about your issue. iPay strives to respond to all requests and complaints within a reasonable time.