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Privacy Policy

Privacy Policy

MistralPay is committed to protect the privacy of individuals who visit the website and who make use of the online facilities. The policy can be easily accessible via a link at the bottom of each web page.

Data Controller

The Data Controller of this website is Mistral Pay LTD whose office is situated at Ground Floor, Europa Centre, St. Anne Street, Floriana, FRN 9011, MALTA

Information Collected and Purpose

Personal Information Collected

We collect personal information to provide you with our Services. When we require certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our Services when you do choose not to share certain information with us.

For example, we collect personal information which is required under the law to open an account, add a payment method, or execute a transaction. We also collect personal information when you use or request information about our Services, subscribe to marketing communications, request support, complete surveys, or sign up for a MISTRAL PAY LTD event. We may also collect personal information from you offline, such as when you attend one of our events, or when you contact customer support. We may use this information in combination with other information we collect about you as set forth in this Policy.

Download Information
When you visit our website the following information will automatically be processed and this is solely for the use of this company:

  • The requested web page or download
  • Whether the request was successful or not
  • The date and time when you accessed the site
  • The Internet address of the web site or the domain name of the computer from which you accessed the site
  • The operating system of the machine running your web browser and the type and version of your web browser

We collect the following types of information:

  • Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
  • Formal Identification Information: Tax/ other ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information.
  • Financial Information: Bank account information, transaction history, trading data, and/or tax identification.
  • Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
  • Employment Information: Office location, job title, and/or description of role.
  • Online Identifiers: Geo location/tracking details, browser fingerprint, OS, browser name and version, and/or personal IP addresses.
  • Usage Data: Survey responses, information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data and other data collected via cookies and similar technologies.

How Your Personal Information is Used

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes. We may use this information in the following ways:

To maintain legal and regulatory compliance

Some of our core Services are subject to laws and regulations requiring us to collect and use your personal identification information, formal identification information, financial information, transaction information, employment information, online identifiers, and/or usage data in certain ways. For example, MISTRAL PAY LTD must identify and verify customers using our Services in order to comply with anti-money laundering and terrorist financing laws across jurisdictions. In addition, we use third parties to verify your identity by comparing the personal information you provided against third-party databases and public records. When you seek permissions to send and receive payment, buy and sell limits associated with your Payment Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform the Services in accordance with legal and regulatory requirements.

EEA Residents: For individuals who reside in the European Economic Area (including the United Kingdom) or Switzerland (collectively “EEA Residents”), pursuant to Article 6 of the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively “EEA Data Protection Law”), we process this personal information to comply with our legal obligations.

To enforce our terms in our user agreement and other agreements

MISTRAL PAY LTD handles very sensitive information, such as your identification and financial data, so it is very important for us and our customers that we are actively monitoring, investigating, preventing and mitigating any potentially prohibited or illegal activities, enforcing our agreements with third parties, and/or violations of our posted user agreement or agreement for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected on our Services for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform our Services in accordance with our terms.

To provide MistralPay’s Services

We process your personal information in order to provide the Services to you. For example, when you want to send or receive a payment, we require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information.

To provide Service communications

We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services.

To provide customer service

We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. We may process your information in response to another customer’s request, as relevant. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

To ensure quality control

We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions. Our basis for such processing is based on the necessity of performing our contractual obligations with you.

EEA Residents: For all of the above categories, excluding the first bullet point, pursuant to EEA Data Protection Law, we process this personal information based on our contract with you.

To ensure network and information security

We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.

EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legal obligations.

For research and development purposes

We process your personal information to better understand the way you use and interact with MistralPay’s Services. In addition, we use such information to customise, measure, and improve MistralPay’s Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services. Our basis for such processing is based on legitimate interest.

EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.

To enhance your website experience

We process your personal information to provide a personalised experience and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.

EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.

To facilitate corporate acquisitions, mergers, or transactions

We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes.

EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy our legitimate interests as described above.

To engage in marketing activities

Based on your communication preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. We use information about your usage of our Services and your contact information to provide marketing communications. You can opt-out of our marketing communications at any time.

EEA Residents: Pursuant to EEA Data Protection Law, we process this personal information to satisfy on your consent.

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation. If you choose to so limit the use of your personal information, certain features or MISTRAL PAY LTD Services may not be available to you.

Information from Third Party Providers

From time to time, we may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms.

Public Databases, Credit Bureaus and ID Verification Partners:

We obtain information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. Pursuant to EEA Data Protection Law, our lawful basis for processing such data is compliance with legal obligations. In some cases, we may process additional data about you to ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contract with you and others.

Collection and Use of Information Collected Automatically

We receive and store certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.

For example, we automatically receive and record information on our server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. We may also collect information about how your device has interacted with our website, including pages accessed and links clicked. We may use identifiers to recognise you when you arrive at the Site via an external link, such as a link appearing on a third party site.

Cookies

Cookies are small pieces of data that the site transfers to the user’s computer hard drive when the user visits the website. Our website uses only session cookies which are erased when the user closes the Web browser. The session cookie is stored in temporary memory and is not retained after the browser is closed. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user.

Why We Share Personal Information with Other Parties

We take care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. MistralPay will never sell or rent your personal information. We will only share your information in the following circumstances:

We share your information with third party identity verification services in order to prevent fraud. This allows MistralPay to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.

We may share your information with service providers under contract who help with parts of our business operations such as bill collection, marketing, and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.

We share your information with financial institutions with which we partner to process payments you have authorised.

We may share your information with companies or other entities that we plan to merge with or be acquired by. Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policies.

We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement or any other applicable policies.

If you establish a MistralPay Account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a MistralPay website) will be shared with the owner of the third party website or application and your information will be subject to their privacy policies.

How Personal Information is Shared with Third Party Sites and Services

If you use your MistralPay Account to purchase or sale of goods or services, the seller may also provide MistralPay with your shipping address, name, and/or email to help complete your transaction. This will only be done with your consent. The seller is not allowed to use this information to market their services to you unless you have agreed to it. If an attempt to purchase or sale of goods or services via MistralPay account fails or is partial, we may also provide your seller with details of the unsuccessful transfer.

In connection with a payment between you and a third party, including merchants, a third party may share information about you with us, such as your email address or mobile phone number which may be used to inform you that a payment has been sent to or received from the third party. We may use this information in connection with such transfers to confirm that you are a MistralPay customer, that payments are enabled, and/or to notify you that you have received a payment. If you request that we validate your status as a MistralPay customer with a third party, we will do so. You may also choose to send payment to or request payment from an email address. In such cases, your user name will be displayed in an email message notifying the user of the designated email address of your action.

Please note that merchants you interact with may have their own privacy policies, and MistralPay is not responsible for their operations, including, but not limited to, their information practices. Information collected by third parties, which may include such things as contact details or location data, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

If you authorise one or more third-party applications to access your MistralPay Account, then information you have provided to MistralPay may be shared with those third parties. Unless you provide further authorisation, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using MistralPay Services.

How We Protect and Store Personal Information

We understand how important your privacy is, which is why MistralPay maintains (and requires its service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.

We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in Europe and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to MistralPay or MistralPay staff.

However, we cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorised access to or use of your account.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at the email address or the mailing address listed at the beginning of this Privacy Policy.

Contact and Newsletters

If you have given your consent, MistralPay may contact you via the address, e-mail and / or phone number you provide on your account for marketing, surveys, news and/or similar initiatives.

Encryption of Data Traffic

MistralPay is committed to handling your Customer Information with the highest standards of information security. When your information is transferred over the internet, SSL encryption is used to ensure your sensitive data is not accessible to anyone on the internet.The data that is communicated back and forth between MistralPay and your computer is encrypted with a 256-bit SSL certificate. This means no one can intercept the data stream between MistralPay and your device.

Personal Data Provided by the Data Subject

When using this website’s online facilities, data subjects may be required to provide their personal data for the purposes of fraud prevention, to send newsletter via email from time to time regarding the latest news and useful information about the company’s products/services and/or activities, to release members’ personal information if required by law or if pertinent to judicial authorities or criminal investigations.

MistralPay may also use personal information to provide MistralPay Services and customer support, process transactions and send notices about customer transactions, resolve disputes and troubleshoot problems, prevent illegal and prohibited activities, customise MistralPay Services and content, compare and verify information with third parties.

This information is collected through “traffic data” and may entail the use of “IP addresses” and other numeric codes used to identify a computer. This information may be helpful for statistical purposes and data analysis with an aim at improving and better meeting members’ needs.

MistralPay may also use members’ details to investigate and help prevent potentially unlawful activity or any activity that threatens the network or otherwise violates the user agreement for that service.

Google AdWords

MistralPay uses Google AdWords, a web analytics and search engine advertising campaign management service. Google AdWords uses cookies, web beacons, and other means to help MistralPay analyse how users interact with the site.

You may find Google’s Privacy Statement at http://www.google.com/intl/en/privacypolicy.html.

Google Analytics

MistralPay uses Google Analytics, a web analytics service. Google Analytics uses cookies, web beacons, and other means to help MistralPay analyse how users interact with the site. You may find Google’s Privacy Policy at http://www.google.com/intl/en/privacypolicy.html.

Your Rights as Data Subject

As an individual you may exercise your right to access the data held about you by this company by submitting your request in writing to the Data Controller.

Although all reasonable efforts will be made to keep your information updated, you are kindly requested to inform us of any changes referring to the personal data held by the association.

In any case if you consider that certain information about you is inaccurate, you may request rectification of such data. You also have the right to request the blocking or erasure of data which has been processed unlawfully.

Links to other Web Sites

To give you a better service our site can connect you with a number of links to other local and international organisations and agencies. When connecting to such other websites you will no longer be subject to this policy but to the privacy policy of the new site.

Transaction Security Policy

This site uses Secure Sockets Layer (SSL) to ensure secure transmission of your personal data. You should be able to see the padlock symbol in the status bar on the bottom right hand corner of the browser window. The url address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session will be encrypted or scrambled and then decrypted or unscrambled at the receiving end. This will ascertain that data cannot be read during transmission.

Changes to this Privacy Policy

If there are any changes to this Privacy Policy, we will replace this page with an updated version. It is therefore in your own interest to check the “Privacy Policy” page any time you access our web site so as to be aware of any changes which may occur from time to time.

Feedback

Any comments or suggestions that you may have and which may contribute to a better quality of service will be welcomed and greatly appreciated.

Governing Laws

Information collected through MistralPay will be treated in accordance with current Maltese legislation and the EEA Data Protection

 

Mistral Pay Ltd

Ground Floor, Europa Centre
St. Anne Street
Floriana, FRN9011, Malta

http://www.mistralpay.com
info@mistralpay.com
Skype: mistralpay