Last updated: April 26, 2022
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to GTWS Tech Limited.
- GDPR means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
- EEA means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
- Process in respect of personal data, includes to collect, store, use, restrict, erasure, destruct and disclose to others.
- Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
- Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
- Affiliate means an entity that controls, is controlled by or is under common control with the Company, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Website refers to Solidgate, accessible from https://hub.solidgate.com/
- Service refers to the Website.
- Country refers to: Republic of Cyprus.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- Personal Data is any information that relates to an identified or identifiable individual, such as a name, email, a telephone number, IP address, etc.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Data we collect
Personal Data provided by you through the Website
While registering an account or using Our Website, We may ask You to provide Us with certain Personal Data that can be used to contact or identify You, as well as to reply to your inquiries. Personal Data may include, but is not limited to your:
- Full name
- Email address
- Other data You give us when using Our Website, such as the messages you sent to our support team.
Personal Data of Your customers
As your Processor, we also process the Personal Data of Your customers. We receive these data partially from you and partially directly from your customers. Personal Data may include, but is not limited to your customers’:
- Cardholder name
- Email address
- Telephone number
- IP address
- Address (state, zip code, city)
- Date of birth
- Order description
- Date and amount of transaction
- User ID
- Card Number
- Chosen language
- Device (e.g., operating system) and browser
Personal Data for onboarding of Your company
While onboarding Your company, We may ask You to provide Us with certain Personal Data that are necessary to facilitate the process of Your company’s merchant processing account(s) opening and advising on its maintenance. We collect only such data related to your beneficial owners, principals, officers, authorized representatives that are requested by acquirers to comply with their regulatory requirements. Personal Data may include, but it not limited to:
- Phone number
- Email address
- Residence address
- ID / passport details
- Tax number
- Bank details, personal income and source of wealth
- Employment history and education
- Ownership and directorship in Your company and/or other companies
- Adverse media and law enforcement information
- Presence in PEP, sanction, and watch lists
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.
We use both session and persistent Cookies for the purposes set out below:
Type: Session Cookies
- Necessary / Essential Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Type: Persistent Cookies
- Functionality Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Type: Persistent / Session Cookies
- Analytical Cookies
Administered by: Google
Purpose: These Cookies are used to understand how visitors interact with the Website. These Cookies help provide information on different metrics, such as the number of visitors, bounce rate, traffic source, etc.You can find more information about the individual cookies We use and the purposes for which We use them in the table below:
How do we use Data
When you request us to contact you
Data we collect automatically when You use this Website
When You access the Website, We may collect certain information automatically, including, the Usage Data, Cookies, and similar tracking technologies.
This information is collected for our legitimate interest to improve and to administer Our Service, including data analysis, troubleshooting, statistical and survey purposes.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.
Data we collect as Your gateway services provider
As your gateway services provider, We process some Personal Data of Your customers (e.g., cardholders), such as transaction data necessary to process payments. We make these data available to You through the Website so that You can manage Your payments with Your customers, build Your own analytics and customer support. Also, We process certain Personal Data that are necessary to facilitate the process of Your company’s merchant processing account(s) opening and advising on its maintenance. We collect only such data related to your beneficial owners, principals, officers, authorized representatives that are requested by acquirers to comply with their regulatory requirements.Please note, that as a Personal Data controller, You (merchant) shall bear primary responsibility for the processing of Your customers’ Personal Data, including:
- ensuring the protection of Personal Data in accordance with applicable data protection regulations;
- providing Your customers with necessary information about the processing and the recipients of their Personal Data, such as Our Company;
- supporting the exercise of the rights of Your customers under the applicable legislation, etc;
- When you request us to contact you
Recipients of Data
- Service Providers. If necessary, we may share Your Personal Data with Service Providers to monitor and analyze the use of our Service, to store the Personal Data, to show advertisements to You, to help support and maintain Our Service, to contact You, etc. We have concluded agreements with our Service Providers to protect Your Personal Data.
- Business partners. We may share Your information with Our business partners to offer You certain products, services or promotions.
- Payment services providers. We may share the Personal Data related to Your company’s customers (e.g., transaction data) and representatives (e.g., KYC data) with Your payment services providers to provide Our gateway services.
- Law enforcement.Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
- Other legal requirements. The Company may disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, to protect and defend the rights or property of the Company, to prevent or investigate possible wrongdoing in connection with the Service, to protect the personal safety of Users of the Service or the public, to protect against legal liability.
Data securityWe put security at the forefront of business operations. The Company has implemented a range of technical and organizational measures appropriate to secure Your Personal Data in a manner that takes account of the potential risks for Your interests and rights. We are certified with Payment Card Industry Data Security Standard (PCI Service Provider Level 1). Even though We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Your rightsYou may have the following rights with regard to Your Personal Data:
- to obtain confirmation as to whether or not We process Your Personal Data, and, where that is the case, the information about such processing;
- to request rectification of inaccurate Personal Data;
- to request erasure of Your Personal Data in certain circumstances provided by law;
- to restrict the processing, for example when the processing is unlawful;
- to object to processing of Your Personal Data which is based on a legitimate interest;
- to receive Your Personal Data We process in a structured, commonly used and machine-readable format and to transmit those data to another controller;
- to withdraw any consent that was given at any time.
You also have the right to lodge a complaint with a supervisory authority of the country in which You live or work or the country in which We are located (Cyprus).
ChildrenOur Service does not address anyone under the age of 13, and we request that they not provide Personal Data through the Service. We do not knowingly collect Personal Data from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
Information on Our privacy practices.
- the categories of Personal Data to be collected;
- the purposes for which the categories of Personal Data shall be used;
- the categories of sources from which the Personal Data are being collected;
- the categories of third parties with whom We may share Personal Data.
Access to Your Personal Data.
We may also provide You with specific pieces of Personal Data We has collected about You but no more than twice in a year. To obtain this information from Us, please send an email to email@example.com. which includes “Request for California Privacy Information” on the subject line and Your state of residence and email address in the body of your message. If You are a California resident, We will provide the requested information to You at your email address in response.
- We do not sell Your Personal Data.
Your right to deletion.
You can request that We delete any Personal Data about You which We have collected from You, except for the cases explicitly provided for by the CCPA (e.g., when We need such data to detect security incidents, protect against illegal activity, comply with a legal obligation, etc).
- Information on Our privacy practices.