This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the “Data Subject”) who is not already in the public domain.
The Data Protection Act (DPA) and The General Data Protection Regulation (GDPR), which is EU-wide, seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as KvK.
Who we are
Ginger Payments is an international payments platform principally involved in the B2B sector.
Ginger Payments uses the information collected from you to provide services and marketing information that Ginger Payments believes may be of interest to you and your business. In having made your initial contact with Ginger Payments, you consent to Ginger Payments maintaining a marketing dialogue with you until either you opt out (which you can do at any stage) or we decide to discontinue promoting our services. Ginger Payments also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, Ginger Payments will be acting on the instruction of its client and will aim to ensure that the client is fully GDPR compliant.
Some personal data may be collected about you from forms and surveys that you complete; from records of our correspondence and phone calls; and from details of your visits to our website, including but not limited to personally identifying information such as Internet Protocol (IP) addresses. Ginger Payments may from time to time use such information to identify its visitors. Ginger Payments may also collect statistics about the behaviour of visitors to its website along with transaction information collected in the process of performing its business.
Any information Ginger Payments holds about you and your business encompasses all the details we hold about you and any sales transactions, including any third-party information, we have obtained about you from public sources and our own suppliers, such as credit referencing agencies.
Ginger Payments will only collect the information needed so that it can provide you with its services. Ginger Payments does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that Ginger Payments has purchased from a third-party list broker, on behalf of a client.
Legal basis for processing any personal data
To meet Ginger Payments’s contractual obligations to clients and to conform to relevant legal obligations they have.
Legitimate interests pursued by Ginger Payments and/or its clients
To promote the services offered by Ginger Payments and/or to market the services and/or products offered by Ginger Payments’s existing clients.
Through agreeing to this privacy notice you are consenting to Ginger Payments’s processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing [email protected] See last section for full contact details.
Ginger Payments may, on occasion, pass your Personal Information to third parties exclusively to process work on its behalf. Ginger Payments requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. Ginger Payments does not broker or pass on information gained from your engagement without your consent. However, Ginger Payments may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests. Ginger Payments may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions, to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property, or safety of Ginger Payments, its clients and/or the wider community.
Ginger Payments will process personal data during the duration of any contract and will continue to store only the personal data needed for seven years after the contract has expired to meet any legal obligations. After seven years any personal data not needed will be deleted.
Data is held on multiple servers within EEA. Ginger Payments does not store personal data outside the EEA.
Although Ginger Payments does not store personal data outside of the EEA, in certain circumstances we may need to transfer personal data outside of the EEA in order to provide our services (e.g. when processing transactions through overseas acquiring banks). In such cases, Ginger Payments is committed to ensuring that third party data processors, who may themselves store personal data outside of the EEA, adhere to the highest possible level of data privacy, and, wherever practically possible, will endeavour to impose legally binding obligations on said third parties. This may include, but is not limited to, relying on EU adequacy decisions and/or PCI compliance regulations, and/or enforcing standard contractual provisions.
Your rights as a data subject
At any point whilst Ginger Payments is in possession of or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
- In the event that Ginger Payments refuses your request under rights of access, we shall provide you with a reason, which you have the right to challenge legally. Ginger Payments can, at your request, confirm what information it holds about you and how it is processed.
You can request the following information:
- Identity and the contact details of the person or organisation (Ginger Payments) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Ginger Payments or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (Dutch Data Protection Authority).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it was not collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
- To access details of what personal data is held, identification will be required. Ginger Payments will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence; passport; id card; and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Ginger Payments is dissatisfied with the quality, further information may be sought before personal data can be released.
- All requests should be made to [email protected]
In the event that you wish to make a complaint about how your personal data is being processed by Ginger Payments or its partners, you have the right to complain to Ginger Payments’s DPO. If you do not get a response within 30 days, you can complain to the Dutch Data Protection Authority.
The details for each of these contacts are:
Telephone +31 (0) 205307020 or email [email protected]
Dutch Data Protection Authority