PAYTWEEN, LLC, with registered office at 1405 Langley Place, McLean, VA 22101, USA (henceforth, “Paytween”) is responsible for the Paytween Application (henceforth, “the App”) and informs the User and/or Client of the existence of a personal data file owned by Paytween for which it is responsible.
(1) the data we collect;
(2) the reasons for collecting those data;
(3) the consequences of not providing the data, should the user choose to do so;
(4) how we use these data;
(5) the rights of App Users and Paytween Clients.
This information is important for Paytween and, especially, to its Users and Clients. For this reason, we recommend that you read it carefully.
The Personal Data we collect
We collect Personal Data from Users who are over thirteen (13) years of age because we believe in the importance of preserving the safety and privacy of minors. As such, minors younger than thirteen (13) years of age cannot register with the App. If we find out that a minor under thirteen (13) has registered as a User, we will eliminate his or her information as quickly as possible. We shall collect Personal Data from minors over the age of 13 upon their parent or guardian’s acceptance of the Terms and Conditions, and all other associated policies, of the App.
More specifically, Paytween collects the following data from each User and/or Client (hereinafter, “Personal Data”):
(1) First and last names, a cell phone number, and an e-mail address in order to complete App registration;
(2) The type of device the App is being used with and the web browser model once the App has been downloaded and registration complete;
(3) Profile photo to be used in the App;
(4) Photographs, contents, voice, etc. should the User share them in the chat function of the App. If the User shares photos from the gallery on their mobile device or from their cloud with access from said device, we will request access to said files in order to process the messages which contain them and send them to the recipients;
(5) Telephone numbers in the User’s Contacts.
It is important that the User clearly understands that he or she may provide or share all or some of his or her Personal Data with other Users using the functions offered in the App, such as chat, and in such cases, the User is fully responsible for the consequences of said actions given that it is the User that is communicating with another User who may copy, resend, create other files, etc., actions over which Paytween declines any responsibility.
We may also collect aggregated data, which is to say, data which cannot be linked to one specific person (hereinafter, “Non-Personal Data”). Paytween may collect, process, transfer, and disclose the following Non-Personal Data for any purpose.
Some types of Non-Personal Data, and the purposes for which it will be used, include: language, post code, area in which the App is being used, time zone, etc. In an attempt to get to know what our Users and Clients do with the App, the type of activities they take part in, the amounts they spend, where and how they spend, etc. This is in order to improve our product and offer, where appropriate, additional services and advertising.
The App, the website, and any other Paytween product contain or may contain links to websites, applications, products, and services by other companies, particularly applications and websites for the making of payments. It is important to point out that the collection of data by third parties, particularly sensitive data such as payment information, credit card information, passwords for other payment methods, PIN numbers, etc. is not the responsibility of Paytween, the safekeeping of this Personal Data to be the responsibility of said applications and payment methods. Therefore, Paytween shall not be held responsible in any claim against it resulting from the decision of the User to communicate said data to a third party, it being the responsibility of the User and/or the application, website, or service provided by other companies who collect, store and/or process the data and UNDER NO CIRCUMSTANCES WILL PAYTWEEN BE HELD LIABLE for any claim regarding the processing of data carried out by third parties, such processing it being solely governed by those other companies respective privacy policies. We strongly recommend that Users consult the privacy policies of said third parties. If any Personal Data that you shared with any other website, application, product and service provided by other companies is shared by said third party with Paytween, such Personal Data shall not be stored by Paytween.
We will at all times use information collected about you in accordance with the Data Protection Act 1998.
What’s Paytween’s purpose in collecting Personal Data
The reasons why we collect and process our Clients and Users’ data in Paytween include:
(i) Fulfilling our obligation to comply with the agreement or contract existing between Paytween and our Users and Clients, specifically, the information necessary to complete App registration and allow the App to offer Users and Clients the functions that are the reason the App exists as well as the exchange of messages, with or without content, calculations, information about debts or credits amassed by the other members of the group, etc.;
(ii) Analysis of data with regard to App use and for statistical purposes, improved functioning, the offering of additional services which improve the App, the development of new products and management information;
(iii) Marketing: processing Personal Data for promotional activities;
(iv) Compliance with legal obligations;
(v) Security and Integrity: in the case of the suspicion of fraud and/or abuse of the Paytween App, we can block Users from the App or from access to the App.
(vi) Information: User data allows us to provide information on Paytween products, App updates, events, etc.
(vii) Verification: Paytween may use Personal Data including, for example, date of birth to verify a User’s identity to determine if they are old enough to use the App.
(viii) Important Notifications: occasionally, we will use the data to send Users notifications regarding acquisitions, changes in the functioning of the App or to our General Terms and Conditions, Privacy, Intellectual Property, or Cookies Policies, or any other legal regulation or information regarding the relationship between Paytween and its Users;
(ix) If Users participate in a give-away, a contest, or a promotion, we may use the data provided to administer these programs.
Users may receive marketing emails from Paytween. Users have the ability to opt-out of receiving said marketing emails by following the opt-out instructions provided in the emails. Paytween reserves the right to send you communications relating to your account and use of its website via email, and other means, and these transactional account messages will be unaffected if you elect to no longer receive marketing communications.
What happens if I decide not to consent to the collection and processing of Personal Data
In order to provide the service we offer, Users must provide the necessary information. Otherwise, the application cannot function and thus, the User will neither be able to download it nor to use it.
To whom do we transfer Personal Data
Users authorize Paytween to transfer or communicate Personal Data for all or some of the following reasons:
– Compliance with legal obligations: regulatory bodies, agencies, etc.
– For statistical purposes, using aggregate data, for ratings, audience, dissemination, and use; for economic viability and financing, etc.
– User data may also be processed and used to send Users information and provide services within the App as well as for the communication with users and the execution of promotional activities jointly with third parties to whom Paytween may communicate information and aggregate, non-identifiable Personal Data, commercial offers and advertising of its products by any means, whether physically or digitally, expressly including e-mail.
– Paytween may share Personal Data and Non-Personal Data with other companies dedicated to any of the following activities, inter alia: data processing on behalf of Paytween, offering its products, meeting the orders of clients, customer services, analysis of customer’s interest in our products and services, surveys and promotions. These companies are required to take commercially reasonable steps to protect the data and may be located in any country.
– Similarly, in certain cases it is possible that Paytween may have the legal obligation to disclose Personal Data, being served with a warrant, in the context of judicial proceedings, or at the request of a public or government authority, both within and outside the User’s country of residence.
– In the case of restructuring, merger, or sale, we will transfer all Personal Data collected to the corresponding third party.
The aforementioned sending of commercial information includes: product presentation, offers for products and services, discounts, packages, promotions, etc. Similarly, the User consents to and authorizes Paytween to process his or her data for the purposes of statistics (segment information by types of products acquired, areas in which the most transactions occur, volume of business by area, etc., inter alia), commerce, and to use any other available marketing tools.
Users may opt out of having their Personal Data shared with any third party for marketing purposes by sending an email to firstname.lastname@example.org stating that they do not wish for their Personal Data to be shared for marketing purposes.
When can Users/Clients access their data
Users may access their data at any time to consult or update it. They may also consult the registry of their activity kept by Paytween in order to decide which type of User data they want to allow to be stored in their account when using Paytween’s services.
Paytween User and Client rights
Likewise, if any User wishes to have his or her Personal Data eliminated, he or she can contact us. However, we reserve the right to not process those requests which are inappropriate or burdensome, which endanger the privacy of third parties, which are not feasible, or which local laws do not require access to.
Requests for access, correction, or elimination of data may be sent to the e-mail address dedicated to privacy issues email@example.com or to the following postal address:
1405 Langley Place
McLean, VA 22101
California Privacy Rights
If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Data by us to third parties for the third parties’ direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content. Applicable Users may email firstname.lastname@example.org to avail themselves of the rights stated in this paragraph.
Do Not Track Signals
Some browsers and services may allow Users to automatically send a “Do Not Track” signal. Our website are not programmed to respond to any “Do Not Track” signal. As such, Paytween does not alter its data collection practices, as described herein, when it receives a “Do Not Track” signal.
Paytween takes commercially reasonable steps to help protect and secure the information it collects and stores about its Users. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Paytween cannot ensure and does not warrant the security of any information you transmit to us.