Privacy Notice

Introduction

NedPay is a brand of Nedsom Financial Services B.V. By using the services under the name NedPay, you acknowledge that all rights associated with this brand belong exclusively to Nedsom Financial Services B.V.

In this policy, the terms "we," "us," and "our" refer to Nedsom Financial Services, the "controller," a foundation under Dutch law, registered in the Chamber of Commerce under number 32088878, with its registered address at Kamp 71, 3811 AP Amersfoort. The terms "you" and "your" refer to you, our customer, and also the data subject whose personal data is being processed.

We are committed to protecting and respecting your privacy. This privacy policy explains what information we collect about you or that you provide to us, what we use it for, and with whom we share this information, in accordance with the General Data Protection Regulation (GDPR). The privacy policy also describes your rights and how you can contact us for more information. Please read the following carefully to understand our principles and practices regarding your personal data and how we handle it. Check this page regularly to stay informed about updates or changes to our privacy policy.

What We Collect/Process

The personal data we collect and process may include, but is not limited to:

• Information you provide to us when using our services, including your name, date of birth, address, contact information (email address, phone number), payment details (bank account number, credit card number), and proof of identity (passport, ID card, or driver's license, etc.).
• To deliver our services, we may also require information about third parties, such as the name and contact details of the sender.
• Information about your use of our services, such as your transaction history, how you use our services to send or receive money (computer, app, mobile, etc.), and to whom you send money.
• Additional information from you or third parties to prevent or detect crime or to help combat fraud, money laundering, and terrorist financing.
• To ensure you receive our website and its content in the best possible way, we may also collect information about your computer, operating system, and browser. This data is also used for internal operations, such as troubleshooting, data analysis, testing, research, and for statistical and research purposes.

How We Use Your Information

Our primary goal in collecting information is to provide you with a smooth, safe, and efficient service. Additionally, we use this information for the following purposes:

• To process your transactions.
• To verify your identity.
• To inform you about changes to our services.
• To collect payments from you.
• To provide you with information about transactions you have made or other information regarding our services.
• To notify you of marketing news, offers, or other updates.
• To improve our service to better meet your needs.
• To combat fraud.
• To comply with anti-money laundering and terrorist financing laws and regulations.

Legal Basis for Processing Your Personal Data

To comply with our legal obligations, we are required to collect your personal information. This information is necessary to verify your identity. Furthermore, we are legally required to retain transaction data and communications with you for a certain period.

We process your personal data and that of relevant third parties to fulfill our agreements with you and to provide our services as effectively as possible. For example, we require this information to process your transaction and collect payments.

When you have given us specific consent to process certain personal data, you may withdraw that consent at any time. We will then stop processing such data. If no other legal obligations require us to retain your personal data, we will delete your data from our system.

Sharing Your Information

We may share your information:

• With external service providers that assist us with our business operations, such as transaction processing, fraud prevention, communication, support, and marketing. These service providers may only use your personal data as necessary to provide these services to us.
• To comply with legal obligations, we may share data with legal authorities. This is only done after a formal request or in cases of suspected fraud or illegal activities.
• With companies that we engage to provide services to or for us.
• In cases of potential investments or restructuring.

We will not share your data for commercial purposes unless you have explicitly given your consent.

How We Protect Your Data

We take the protection of your data seriously and implement appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized modification. For instance, when you enter your bank details, these are always encrypted.

Transferring Data Outside the EEA

Personal data provided through our website or app is transmitted to and stored on secure servers owned or operated by us within the European Economic Area (EEA). Such data may be transferred to or stored at a location outside the EEA and may also be processed by partners outside the EEA who work for us or one of our service providers. Such transfers are made to provide our services, improve our service, or assist with our security and fraud protection activities.

When recipients are outside the EEA, we will ensure that they provide an adequate level of protection for your personal data or that the transfer is permitted under applicable data protection laws, for example, by using standard contractual clauses approved by the European Commission, relying on a relevant adequacy decision by the European Commission, or other legal grounds in compliance with applicable law.

Retention Period

Depending on the purpose for which your data is used, the retention period may vary. We will only retain the information we collect about you as long as necessary for the aforementioned purposes or as required to comply with legal obligations. Generally, we are required to retain customer records, including all information, for up to five years after the most recent transaction of a customer.

Your Data, Your Rights

You always have the right to:

• Be informed about how we use your data.
• Modify or update your data if you believe it is incorrect or inaccurate.
• Request access to or receive a copy of the personal data you have shared with us and transfer it elsewhere.
• Object to the processing of your personal data under certain circumstances and/or restrict such processing.
• Not be subject to decisions made solely through automated processing.

You can contact us at any time regarding these rights. Please note that certain exceptions may apply due to laws and regulations relevant to regulated financial institutions like us.

Use of Cookies

By using our services, you agree to our use of cookies on this site.

A cookie is a small text file that is stored on your computer or phone to identify your web browser or to store information or settings in your web browser. We use cookies to identify and analyze which pages a user has visited, helping us improve our service and tailor it to individual users. The information is used to enhance the user experience as well as for statistical and marketing purposes.

Cookies never give us access to your computer or any information about you, except for the data you choose to share with us. You can choose to accept or decline cookies. If you no longer wish to accept the use of cookies, you can change this in your web browser settings. You can also choose to delete permanent cookies stored on your hard drive. However, declining cookies may limit your ability to fully utilize our services.

Links to Other Sites

Our website may contain links to other websites. We are not responsible for the privacy practices or the content of these other websites. Once you navigate to another website via our website, you are subject to that website's terms. We recommend familiarizing yourself with the privacy practices of those other sites before providing them with your personal data.

Contact

If you have questions, requests, or comments about this privacy policy or the use of your personal data, please contact us by email at: support@nedsom.eu.

If you believe we have not adequately addressed your question, request, or concern, you have the right to file a complaint with the national supervisory authority, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). This can be done via the following link:

https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons