1.1. Bedford Pay Ltd is a company incorporated under the laws of England and Wales with registration number 11082273, whose registered office is at 3rd Floor, 207 Regent Street, London, United Kingdom, W1B 3HH. We are regulated by the Financial Conduct Authority (Reference 900933) under the Electronic Money Regulations 2011 for the issuance of e-money.
1.2.1.visit our website;
1.2.2.fill in an application form;
1.2.3.communicate by email;
1.2.4.communicate by telephone;
1.2.5.communicate by internal massaging system.
1.3.We are committed to safeguarding your personal information. Whenever we process your personal information, we are processing it in line with the General Data Protection Regulation.
1.4. Bedford Pay Ltd offers payment services as a Small Electronic Money Institution
2. What information we will collect about you
2.1.We, or third parties on our behalf, may collect and use any of the following information about our client’s:
· client’s first and last name;
· client’s company and/or personal email address;
· client’s telephone number;
· client’s company name;
· client’s job title;
· client’s company’s industry, trade details and regulated status;
· general information about client’s interest in our – products and Services;
· information provided when client’s correspond with us;
· any updates to information provided to us;
· information client’s provide to help us provide client’s with improved Services, for example if we ask client’s to fill in a survey or questionnaire;
· information about client’s marketing preferences;
· details of transactions performed on our platform;
· when you use the Services or a third party processes a payment from you:
· payer name, date of birth, address, banking and identity document details for transactions performed;
· beneficiary name, date of birth, address, banking and identity document details for transactions performed
2.2.Technical Information, this includes: the Internet protocol (IP) address used to connect client’s computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform.
3. How will we use the information we collect about you
3.1.We will collect, use and store the personal information listed above for the following reasons:
3.1.1.to provide client’s with our Services and Website;
3.1.2.to perform transaction screening in order to identify transactions which involve fraud, money laundering or criminal offences, or are contrary to legal or regulatory requirements on us. This involves a type of automated decision making that may reject your transaction where its characteristics trigger a concern in relation to these areas;
3.1.3.to deal with any enquiries client’s have about our Services and Website;
3.1.4.to provide support for any issues client’s might have with our Services or Website, and undertake improvement and maintenance of our Services and Website;
3.1.5.to send client’s certain communications (including by email) about our and Bedford Pay Services such as service announcements and operational messages (for example, about down time or maintenance);
3.1.6.to carry out statistical analysis and market research on people who may be interested in our Services;
3.1.7.to comply with our legal and regulatory obligations in relation to our Services (for example, to comply with the relevant Financial Conduct Authority regulatory requirements and guidance); and
3.1.8.if you have provided a personal email address and consented or, otherwise, if it is in our legitimate interests, for business development and marketing purposes, to contact you (including by email or post) with information about our Services which either you request, or which we feel will be of interest to you (including newsletters).
3.2. Whatever our relationship with client’s, we may also collect, use and store your personal information for the following additional reasons:
3.2.1.to deal with any enquiries or issues client’s have about how we collect, store and use client’s personal information, or any requests made by client’s for a copy of the information we hold about you. If we do not have a contract with client, we may process client’s personal information for these purposes where it is in our legitimate interests for customer services purposes;
3.2.2.for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
3.2.3.to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so;
3.2.4.to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so
4. Legal basis for use of clients personal information
4.1.We consider that the legal bases for using your personal information are as follows:
4.1.2.our use of clients personal information is necessary for complying with our legal obligations (for example, complying with our regulatory obligations to the Financial Conduct Authority); or
4.1.3.where neither (4.1.1.) nor (4.1.2.) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our Website). Our legitimate interests are to:
220.127.116.11.run, grow and develop our business;
18.104.22.168.operate our Website;
22.214.171.124.select appropriately skilled and qualified suppliers;
126.96.36.199.marketing, market research and business development;
188.8.131.52.provide efficient and effective Services to our customers, make and receive payment and provide customer services;
184.108.40.206.place, track and ensure fulfillment of orders with our suppliers; and
220.127.116.11.for internal group administrative purposes.
4.1.4.Where you have provided a personal email address to us, we may process your personal information in some cases for marketing purposes on the basis of your consent.
5. Sharing of your information with others
5.1.We will only share your personal data to fulfil our obligations related to payment services we provide. Your personal data may be shared with:
5.1.1.Selected third parties for the execution of any contract we enter into, this includes exchanging information with other companies and organisations for the purposes of Compliance, AML and fraud protection:
5.1.2.With authorized entities, if we are obligated to disclose or share your personal data in order to comply with any legal reasons, or in order to enforce or apply our Terms and Conditions and other agreements.
6. How long will your information be retained
6.1.We will keep Customer information only as long as necessary.
6.2.All transaction data will be kept for 6 years as we are required by law to keep this information. 6.3.When our relationship with our client ends, we will keep information for 6 years after the contract end date.
6.4.If application to become Bedford Pay client was not approved we will keep your details for 12 months.
7. Where are we storing our information
7.1.The personal data provided is stored in a secure hosting environment based in the UK and EU.
7.2.The transaction data that we collect will be transferred to, and also stored at, a destination outside the European Economic Area ("EEA"). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. To ensure your data is secure and we comply with our privacy obligation, we have data processing agreements and security operational and technical measures in place with these suppliers.
7.3.All payment transactions are encrypted using SSL technology. When we have given, or when Client has chosen a password which enables it to access our web-based platform, it is responsible for keeping this password confidential.
7.4.We employ a range of technology and procedures to ensure that this data is secure, including encryption, anti-virus and anti-malware software, intrusion detection, company-wide data usage policies, and mandatory security and privacy staff training.
7.5.Transmission of information via the internet is not 100% secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8. Access rights. In line with the GDPR regulations, you have the following rights:
8.2.You have the right to access the information we hold for you by making a Subject Access Request, by emailing [email protected].
8.3.You have the right for inaccurate or incomplete data we hold to be updated. You can make a request to have your data updated by emailing [email protected].
8.4.You may have the right to be forgotten in the circumstances where we are not obliged by law to keep your information. If you wish to exercise this right please contact us by emailing [email protected].
8.5.You have the right to restrict processing when you have exercised one of the above right and it may take some time to process that request. For example: when you contact us to update your details you have the right to request restriction until your details have been updated
8.6.For the processing activities where we have asked you for consent, you have the right to withdraw this consent at any point by emailing [email protected].
8.7.You can object to the processing of your personal data at any point by emailing [email protected]. There may be instances where we may not be able to fulfil those requests, but we will provide you with explanation when replying back to you.
8.8.Bedford Pay does not undertake any automated processing or profiling.
8.9.If you have provided us with your personal data with consent or under the contact obligations, you have the right to request the data you have provided to us in a machine-readable format should you decide to move to another data controller.
8.10.If you feel we have been intrusive to your privacy or misused your data you have the right to complain to the Information Commissioner’s Office https://ico.org.uk/for-the-public/raising-concerns.
9.2.Strictly necessary cookies are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
9.3.Analytical/performance cookies allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
9.4.Functionality cookies used to recognise you when you return to our website. This enables us to personalise our content for you, remember your preferences (for example, your login name).
9.5.Targeting cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising more relevant to your interests. We may also share this information with third parties for this purpose.
10. Changes to our privacy notice
11.1.Our site may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.