Privacy Policy

Introduction

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), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulation (GDPR), which is EU-wide and far more extensive, 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 Companies House data.

Open Payment Network Limited (OPN®) is pleased to provide the following GDPR Information:

Who we are

OPN® is an international payment gateway principally involved in the B2B sector.

Personal Data

OPN® uses the information collected from you to provide services and marketing information that OPN® believes may be of interest to you and your business. In having made your initial contact with OPN®, you consent to OPN® 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. OPN® also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, OPN® 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. OPN® may from time to time use such information to identify its visitors. OPN® may also collect statistics about the behaviour of visitors to its website along with transaction information collected in the process of performing its business.

OPN’s® website uses cookies, which are strings of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. OPN® website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using OPN’s® website.

Any information OPN® 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.

OPN® will only collect the information needed so that it can provide you with its services. OPN® does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that OPN® has purchased from a third-party list broker, on behalf of a client.

Legal basis for processing any personal data

To meet OPN’s® contractual obligations to clients and to conform to relevant legal obligations they have.

Legitimate interests pursued by OPN® and/or its clients

To promote the services offered by OPN® and/or to market the services and/or products offered by OPN’s® existing clients.

Consent

Through agreeing to this privacy notice you are consenting to OPN’s® processing your personal data for the purposes described. You can withdraw consent at any time by emailing [email protected]; by phoning +44 (0) 1823 365685; or by writing to us.  See last section for full contact details.

Disclosure

OPN® may, on occasion, pass your Personal Information to third parties exclusively to process work on its behalf. OPN® requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. OPN® does not broker or pass on information gained from your engagement without your consent. However, OPN® may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests. OPN® 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 OPN®, its clients and/or the wider community.

Retention policy

OPN® 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 storage

Data is held on multiple servers within the United Kingdom. OPN® does not store personal data outside the EEA.

Data transfers

Although OPN® 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, OPN® 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 OPN® 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 OPN® refuses your request under rights of access, we shall provide you with a reason, which you have the right to challenge legally. OPN® 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 (OPN®) 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 OPN® 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 (ICO).
• 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. OPN® will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence; passport; birth certificate; 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 OPN® is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to [email protected] or by phoning +44 (0) 1823 365685 or by writing to us at the address further below.

Complaints

In the event that you wish to make a complaint about how your personal data is being process by OPN® or its partners, you have the right to complain to OPN's® DPO. If you do not get a response within 30 days, you can complain to the ICO.

The details for each of these contacts are:
Open®Payment Network Limited, FAO Data Protection Officer (DPO)
Heron Gate, Birches Corner, Taunton, Somerset, TA1 2LOP
Telephone +44 (0) 1823 365685 or email [email protected]

ICO
Wycliffe House, water Lane, Wilmslow, SK9 5AF
Telephone +44 (0) 303 123 1113 or email https://ico.org.uk/global/contact-us/email