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Privacy Policy for PayPal Services

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Privacy Policy for PayPal Services

Last Update: Oct 18, 2013

 

Jump to section:

1. Overview
2. Binding Corporate Rules
3. Information We Collect
4. Our Use and Disclosure of Information
5. Information Security
6. Accessing and Changing Your Information
7. Accountability
8. IMPORTANT DATA PROTECTION INFORMATION FOR USERS RECEIVING PAYMENTS THROUGH WEBSITE PAYMENTS PRO (INCLUDING VIRTUAL TERMINAL) AND/OR PAYPAL HERE*
 
This Privacy Policy applies to all European Union countries except Austria, Belgium, Croatia, Denmark, Finland, France (including French Guiana, Guadeloupe, Martinique, Reunion and Mayotte), Germany, Italy (including the Vatican City), Luxembourg, Netherlands, Poland, Portugal, Spain and Sweden.

Please view, read, download and save this policy.

The Privacy Policy below governs your use of your PayPal account and products, services and any other features, technologies or functionalities offered by us (collectively "the PayPal Services") (including, without limitation, any information you provide in relation to the PayPal Services).

 

1. Overview

In order to operate the PayPal Services and to reduce the risk of fraud, PayPal (Europe) S.à r.l. et Cie, S.C.A. ("PayPal", “our”, “us” or "we"), the data controller, must ask you to provide us with information about yourself, including your credit or debit card and/or bank account details. By consenting to, and agreeing the terms of, this Privacy Policy, you expressly consent and agree to us processing your data in the manner set out herein. This Privacy Policy describes the information we collect and how we use that information. PayPal takes the processing of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy.

We will not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. However, in order for us to offer our services to our users; enhance the quality of our service from time to time; and protect the interests of our users, we will in limited circumstances share some of your personal information with third parties under strict restrictions, as described in more detail in the section "Our Use and Disclosure of Information". It is important for you to review this Privacy Policy as it applies to all the PayPal Services.

By accepting the Privacy Policy at registration, you expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

All future changes to this Privacy Policy set out in the Policy Update  already published on the “Legal Agreements” landing page of the PayPal website at the time you register for the Services are incorporated by reference into this Privacy Policy and will take effect as specified in the Policy Update. “Policy Update” means a prior notice of changes to any of your agreements with PayPal which PayPal may make available to you in writing. If you disagree with the terms of this Privacy Policy, please do not register for or use the PayPal Services.

Notification of Changes

This Privacy Policy may be revised over time as new features are added to the PayPal Services or as we incorporate suggestions from our customers. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it. In addition, if we propose to change this Privacy Policy in a substantial manner, we will provide you with at least 30 days' prior notice of such a change. We may post the notice on the "Policy Updates" page of our website(s) and/or send the notice by e-mail. After this 30 days' notice, you will be considered as having expressly consented to all amendments to the Privacy Policy. If you disagree with the terms of this Privacy Policy, you may close your account at any time.

Please check the PayPal website at https://www.paypal.com/uk/ at any time for the most current version of our Privacy Policy.

Some pages on the PayPal website include links to third-party websites. These sites are governed by their own privacy statements, and PayPal is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third-party websites should review the privacy statements of these sites before providing them with personally identifiable information.

For the avoidance of doubt, this Privacy Policy does not constitute a "framework contract" for the purpose of the EU Payment Services Directive (2007/64/EC) or any implementation of that directive in the European Union or EEA (including, without limitation, the UK Payment Services Regulations 2009).

A Special Note about Children

Children are not eligible to use our service and we ask that minors (persons under the age of 18) do not submit any personal information to us or use the PayPal Services.

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2. Binding Corporate Rules

In addition to the privacy practices set out in this Privacy Policy, eBay Inc., the ultimate parent company of PayPal, has established a set of Corporate Rules (also referred to as Binding Corporate Rules), approved by a number of European Union data protection regulators. These Corporate Rules are a commitment by eBay Inc. to adequately protect your personal information regardless of where the data resides, and depending upon your location, may provide additional rights through your data protection regulator or a court. If you would like additional information regarding our Corporate Rules please contact us.

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3. Information We Collect

Required Information

To open a PayPal account or use the PayPal Services, you must provide your name, address, phone number, and email address. In order to make payments through the PayPal Services, you must provide credit card, debit card or bank account information. We also ask you to choose two different security questions to answer (such as your city of birth or your pet's name). This required information is necessary for us to process transactions, issue a new password if you forget or lose your existing password, protect you against credit card fraud and current account fraud, and contact you should the need arise in administering your account or the PayPal Services.

We will also require other commercial and/or identification information if you send or receive certain high-value transactions or high overall payment volumes through the PayPal Services or as is otherwise required in order for us to comply with our anti-money laundering obligations under European law.

When you access PayPal using a mobile device (e.g. a smartphone), we may additionally collect and store device sign-on data (including device ID) and geolocation data in order to provide our services.

If you use certain functionalities provided by us (such as the PayPal POS Functionality available in your mobile app) we may ask you to upload a picture of you in order to provide these specific services.

Transaction Information

When you use the PayPal Services to send money to someone else or request money from someone else, we ask you to provide information related to that transaction. This information includes the amount and type of the transaction (purchase of goods, purchase of services, or simple money transfer) and the email address, Skype ID (if applicable) or phone number of the third party. Also, when you send money to another PayPal customer, you may be asked to provide personal details to that customer to complete the transaction. Those details may also be passed on to us from that customer. We retain this information for each of your transactions through the PayPal Services and may add this information to your account profile to be used for future transactions that you may make with us. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to access your PayPal account or use the PayPal Services, in order to help detect possible instances of unauthorised transactions.

Information about You from Third Parties

In order to protect all our customers against potential fraud, we verify the information you provide with the "Payment Processors" and/or "Credit Reference and Fraud Agencies" listed in the table under the section "Disclosure to Third Parties other than PayPal Customers" below. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card or bank account with PayPal, we will use card authorisation and fraud screening services to verify that your bank or card information and address match the information you supplied to PayPal, and that the card has not been reported as lost or stolen.

If you send or receive high overall payment volumes through the PayPal Services, or if as a merchant have limited selling history, in some circumstances we will conduct a background check on your business by obtaining information about you and your business, and potentially (if legally permitted) also about your directors, shareholders and partners, from a credit reference or fraud agency such as Dun & Bradstreet, as listed in the table under the section entitled, "Disclosure to Third Parties other than PayPal Customers" below. If you owe us money, we may conduct a credit check on you by obtaining additional information about you from a credit reference or fraud agency, to the extent permitted by law. PayPal, at its sole discretion, reserves the right to periodically retrieve and review a business and/or consumer credit report supplied by such credit reference or fraud agency for any account, and reserves the right to close an account based on information obtained during this credit review process.

If you use your PayPal account to sell items, we may also collect public information about your business and your behaviour on social media platforms (such as the e-mail address and the number of “likes” and “followers”), to the extent relevant to confirm an assessment of your transactions and/or your business, including its size and the size of its customer base.

We may also collect information from members of the eBay Inc. corporate family or other companies (subject to their privacy policies). If you are sending transaction related communication on PayPal’s or eBay’s conflict resolution platforms to your buyer or seller, we may collect such information in order to assess your transactions and any risk associated with your activities, as well as for fraud detection, prevention, and or remediation of fraud, or other illegal actions or to detect, prevent or remediate violations of policies or the applicable user agreements.

Additional Verification

If we cannot verify the information that you provide, or if you request a withdrawal by cheque to an address other than your verified credit card billing address, we may ask you to upload or send us additional information by fax (such as your driving licence, credit card statement, and/or a recent utility bill, or other information linking you to the applicable address), or to answer additional questions online to help verify your information.

Website Traffic Information

Because of the way Internet communication standards work, when you arrive at or leave the PayPal website, we automatically receive the web address of the site that you came from or are going to. We also collect information on which pages of our website you visit, IP addresses, the type of browser you use and the times you access our website. We use this information to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our services and your experience with PayPal.

Our Use of Cookies, Web Beacons, Local Storage and Similar Technologies

When you visit or interact with our sites, services, applications, tools, advertising, and messaging (such as email), we or our authorised service providers may use cookies, web beacons, and other similar technologies for storing information to help provide you with a better, faster, and safer experience. This page is designed to help you understand more about these technologies and our use of them on our sites and in our services, applications, and tools.

Below is a summary of few key things you should know about our policy related to the use of such technologies. You can review our full policy here.

We offer certain site features, services, applications, and tools that are available only through our use of these technologies. You are always free to block, delete, or disable these technologies if your browser or device so permits. However, if you decline cookies or other similar technologies, you may not be able to use certain site features, services, applications, or tools. You may also be required to re-enter your password more frequently during a session. For more information on how you can block, delete, or disable these technologies, please review the Help section of your browser, add-on, application, or device.

Where applicable, we protect our cookies and other similar technologies so that only we and/or our authorised service providers can interpret them by assigning them a unique identifier that is designed for interpretation only by us. You may encounter cookies, web beacons, or other similar technologies from authorised third parties, commonly called service providers, that we have contracted with to assist us with various aspects of our site operations, or to provide you our services, applications, and tools. We use both “session” and “persistent” cookies, as well as first-party and third-party cookies and similar technologies.

Our uses of these technologies fall into the following general categories

  • Operationally Necessary – allow us to operate our sites, services, applications, and tools, and ensure their safety and security, and allow you to access these sites, services, applications, and tools;
  • Performance-Related – are useful in order to assess the performance of our sites, services, applications, and tools;
  • Functionality-Related – offer you enhanced functionality when using our sites, services, applications, and tools; and
  • Advertising- or Targeting-Related – are used by us or our third-party advertising providers to deliver content, including advertisements relevant to your interests.

We may work with third-party companies, commonly known as service providers, who may place third-party cookies, web beacons, or similar technologies for storing information on our sites or in our services, applications, and tools with our permission. These service providers help us operate our sites, applications, services, and tools, and provide you with a better, faster, and safer experience;

Our sites, services, applications, and tools may use third parties, such as network advertisers and ad exchanges, to serve advertisements. These third-party ad networks and exchange providers may use third-party cookies, web beacons, or similar technologies to collect information to provide you with their services. They may also collect your device identifier, IP address, or identifier for advertising (IDFA), which may be used to tailor the advertising you see on our sites or elsewhere on the web.

Customer Service Correspondence

If you send us correspondence, including emails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from PayPal to you. We retain these records in order to keep records of our relationship, to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

Questionnaires, Surveys and Profile Data

From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

Recipients without registered PayPal Accounts and Requests

When a registered PayPal user either sends a payment to, or requests a payment from, an individual who is not a registered PayPal user, we will retain the information that the registered PayPal user submits to us, including, for example, the other party's email address, Skype ID (if applicable), phone number and/or name, for the benefit of the registered PayPal user who is attempting to contact the other party, so that the registered PayPal user can see a complete record of his or her transactions, including uncompleted transactions. Although this information is stored for a certain period of time, we will not market to the non-registered person in any way at any time. Additionally, these persons have the same rights to access and correct information about themselves (assuming that their details were correct) as anyone else who uses the PayPal Services. 

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4. Our Use and Disclosure of Information

Internal Uses

We collect, store and process your personal information on servers located in the United States and operated by our parent company, PayPal Inc and elsewhere in the World where PayPal facilities are located. Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customised experience. You agree that we may use your personal information to:

  • provide the services and customer support you request;
  • resolve disputes, collect fees, and troubleshoot problems;
  • detect, prevent, and/or remediate fraud or other potentially illegal or prohibited activities, or to detect, prevent or remediate violations of policies or applicable user agreements;
  • customise, measure, and improve our services and the content and layout of our website;
  • deliver targeted marketing and advertising, service updates, and promotional offers based on the communication preferences you have defined for your PayPal account (please refer to the section "Our Contact with PayPal Customers" below) and your activities when using the PayPal Services; and
  • compare information for accuracy, and verify it with third parties.

Marketing

We may combine your information with information we collect from other companies and use it to improve and personalise the PayPal Services. If you don't wish to receive marketing communications from us or participate in our ad-customisation programmes, simply log in to your account, select My Account, Profile, then My account settings and update your Communication preferences, or follow the directions provided with the communication or advertisement.

Disclosure to Other PayPal Customers

If you are a registered PayPal user, your name, email address, Skype ID (if applicable), phone number (if applicable) date of sign-up, the number of payments you have received from verified PayPal users, and whether you have been verified to have control of a bank account are made available to other PayPal customers whom you have paid or senders who are attempting to pay you using the PayPal Services. If you are a Business account holder, we will also display to other PayPal customers the website address (URL) and customer service contact information that you provide us. In addition, this and other information may also be shared with third parties when you use these third parties to access the PayPal Services. However, your credit card number, bank account and other financial information will not be revealed to anyone whom you have paid or who has paid you through the PayPal Services or third parties that use the PayPal Services, except with your express permission or if we are required to do so pursuant to credit card rules, a court order or other legal process.

If you are buying goods or services and pay through PayPal, we may provide the seller with the delivery address for the goods and your billing address to complete your transaction. If an attempt to pay your seller fails, or is later invalidated, we may also provide your seller with details of the unsuccessful payment. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.

If you are using the PayPal POS Functionality on your mobile app, we may share your picture that you have stored with your mobile app with the seller with whom you are attempting to transact in order to verify your identity, as well as the fact that that you are within local reach as a customer.

We work with third parties including merchants to enable them to accept or facilitate payments from or to you using the PayPal Services. In doing so, a third party may share information about you with us such as your email address or phone number, when a payment is sent to you or when you are attempting to pay that third party. We use this information to confirm that you are a PayPal customer and that PayPal can be enabled to make a payment, or where a payment is sent to you to send you a notification that you have received a payment. Also, if you request that we validate your status as a PayPal customer with a third party, we will do so. Please note that third parties you buy from and contract with may have their own privacy policies, and PayPal is not responsible for their operations, including but not limited to their information practices.

By accepting this Privacy Policy, you expressly agree and consent that each time you pay or attempt to pay another PayPal customer(including a merchant) using your PayPal account, PayPal may transfer the aforementioned relevant data to such PayPal customer, who may be located outside the European Economic Area (EEA), in order to process, execute or otherwise deal with and provide information about the payment. You also expressly agree and consent to PayPal providing transactional information and other information necessary for the use of a PayPal mobile application (including point of sale products) to a merchant or another PayPal customer who you have explicitly selected or chosen using the PayPal mobile application or point of sale product.

If you open a PayPal account directly on a third- party website or via a third party application, any information that you enter on that website or application (and not directly through the PayPal Services) will be shared with the owner of such third party website or application and your information may be subject to their privacy policies. 

Disclosure to Third Parties other than PayPal Customers

PayPal will not sell or rent any of your personal information to third parties for their marketing purposes without your explicit consent, and will only disclose this information in the limited circumstances and for the purposes described in this policy. This includes transfers of data to non-EEA member states. Specifically, you consent to and direct PayPal to do any and all of the following:

  1. Disclose information including, without limitation, transaction information, account information, personal information and the contents of communications to: the police; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies (other than tax related authorities), departments, regulatory authorities, self-regulatory authorities or organisations (including, without limitation, the Agencies set out in the table under the heading "Agencies" below); and other third parties, including Group companies, that we in good faith believe it is appropriate for us to cooperate with in investigations of fraud or other illegal activity or potential illegal activity, or to conduct investigations of violations of our User Agreement (including without limitation, your funding source or credit or debit card provider). If false or inaccurate information is provided by you and fraud is identified, details will be passed by us to fraud prevention agencies and law enforcement agencies may access and use that information. We and other organisations may also access and use (including from other countries) this information and the information recorded by fraud prevention agencies to prevent fraud and money laundering. Please contact us if you want to receive further details of the relevant fraud prevention agencies.
  2. Disclose information in response to the requirements of the credit card associations or a civil or criminal legal process.
  3. If you as a merchant use a third party to access or integrate PayPal, we may disclose to any such partner the status of your PayPal integration, whether you have an active PayPal account and whether you may already be working with a different PayPal integration partner.
  4. Disclose information to the "Categories" of third parties listed in the table below. The purpose of this disclosure is to allow us to provide our services to you. We also set out in the table below, under each "Category", non-exclusive examples of the actual third parties to whom we currently disclose your account information, together with the purpose of doing so, and the actual information we disclose (except as explicitly stated, these third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information was shared).

Category

Party Name and Jurisdiction (in brackets)

Purpose

Data Disclosed

Payment Processors

 

HSBC Bank Plc (UK, Ireland), HSBC Merchant Services LLP (UK), Bank of America (UK, USA, Italy, and India), Discover Financial Services (USA), JPMorgan Chase Bank (UK, USA), BNP Paribas (France), Netgiro (Sweden), StarFinanz (Germany), Wells Fargo (Ireland, USA), American Express (USA), National Westminster Bank PLC (UK), OmniPay Limited (Ireland), Australia and New Zealand Banking Group Limited (Australia), ANZ National Bank Limited (New Zealand) and Transaction Network Services (UK) Limited (UK)

To allow payment processing settlement services, and fraud checking.

Name, address, details of user funding instruments, and details of payment transactions.

 

Deutsche Bank AG (Germany, Netherlands, France, Spain)

To allow the processing of direct debits in Germany, Netherlands, France and Spain.

Name, date of transaction, amount, currency and user’s bank account information.

 

Royal Bank of Scotland plc (UK) (“RBS”)

To allow payment processing and dispute handling for transactions of PayPal users when those users transact with a merchant who uses the PayPal service via the RBS service.

All account information except details of user financial instruments.

 

Visa Europe Ltd (UK) including Visa’s VMAS system; Mastercard International Incorporated. (USA) including Mastercard’s MATCH system

To share risk and fraud information in the mandatory credit card company’s database regarding the conduct of a merchant’s account thereby reducing exposure to fraud and breaches of scheme rules and standards.

All account details of merchant account, and circumstances and conduct of the account

Audit

 

PricewaterhouseCoopers Sàrl (Luxembourg)

To test PayPal’s Anti Money Laundering (AML) and Know Your Customer (KYC) controls and to carry out professional auditing services for PayPal Inc. and its subsidiaries.

For a sample of individual customer accounts:
name, PayPal account number (Customer ID), total amount received on the PayPal account, total amount sent from the PayPal account, type of PayPal account, and, as the case may be, any other relevant account information.

Customer Service Outsourcing

 

Sutherland Global Services Inc. (USA and Philippines), Sitel GmbH (Germany), Transcom Worldwide SAS (France, Tunisia), Transcom Worldwide France SAS (France), Transcom Worldwide SpA (Italy), Competence Call Center Leipzig GmbH (Germany), Convergys Customer Management Group Inc. (USA), Arvato Direct Services GmbH (Germany) and Concentrix Europe Limited (UK)

To allow telephone and email customer support services.

Name, address, phone number, email addresses, truncated and limited or full funding source information (case dependent), funding source expiration dates, type of PayPal account, proof of identity, account balance and transaction information, customer statements and reports, account correspondence, shipping information, and promotional information.

 

Nuance Communications Inc. (USA)

To calibrate and optimise speech recognition performance for telephone customer support services.

Recordings of a sample of customer support telephone calls, which may include any or all account information transmitted during the call.

 

ICT Group Inc. (US)

To perform and facilitate telephone customer support.

Name, address, phone number, and PayPal account number.

 

Lithium Technologies Inc. (USA)

To provide member-to-member platform services and customer service on our customer community platforms.

Name, email address, PayPal single sign on ID (PayPal SSN ID)

 

ILinc Communications, Inc. (USA)

To provide webinars (online seminars) to merchants on ILinc’s platform.

Name, email address of merchants

 

ePerformax Contact Centers & BPO (USA), Genpact International Inc. (USA)

Customer services regarding payments relating to North America and Asia

Name, address, phone number, email addresses, truncated and limited or full funding source information (case dependent), funding source expiration dates, type of PayPal account, proof of identity, account balance and transaction information, customer statements and reports, account correspondence, shipping information, and promotional information.

Credit Reference and Fraud Agencies

Please note that in addition to the stated purposes below, PayPal uses your personal information to detect, prevent, and/or remediate fraud or other illegal actions, or to detect, prevent or remediate violations of policies or applicable user agreements.

 

CRIF (Italy), Cerved B.I (Italy), Coface (France), Synectics Solutions Limited (UK), MCL Hunter (UK), GB Group plc (UK), Graydon (UK), iQor Recovery Services Limited (UK), Capita Plc (UK),UK Data Limited (UK), ICC Information Limited (UK), Payment Trust Limited (UK), 192.com (UK), 192.com Limited (UK), i-CD Publishing (UK) Limited (UK), Experian Netherlands BV (Netherlands), Experian Bureau de Credito SA (Spain), Informa D&B SA (Spain), and CRIBIS D&B S.r.l. (Italy).

To verify identity, verify linkage between a customer and its bank account or credit/debit card, assist in making decisions concerning a customer’s credit worthiness (including without limitation, in relation to credit products offered by PayPal), carry out checks for the prevention and detection of crime including fraud and/or money laundering, assist in debt recovery, manage PayPal accounts and undertake statistical analysis, undertake research and testing as to appropriateness of new products and services and system checking.

Please note that data disclosed to these agencies may be retained by the applicable credit reference and fraud agency for audit and fraud prevention purposes.

Name, address, phone number, email address, date of birth, length of time at address, proof of identity, legal form, length of time in business, company registration number, VAT number, funding instrument including bank account and credit /debit card details (if appropriate) and relevant transaction information (if appropriate).

 

Callcredit plc. (UK) including the SHARE database administered by Callcredit, Experian Limited (UK) including databases administered by Experian used for consumer and commercial referencing including CAPS credit searches and CAIS credit account performance data, Equifax Ltd (UK) including the Insight database administered by Equifax, Dun & Bradstreet Limited (UK)

To verify identity, verify linkage between a customer and its bank account or credit/debit card, make decisions concerning a customer’s credit worthiness (including without limitation, in relation to credit products offered by PayPal), carry out checks for the prevention and detection of crime including fraud and/or money laundering, assist in debt recovery, manage PayPal accounts and undertake statistical analysis, undertake research and testing as to appropriateness of new products and services and system checking.

For users of the UK products “Website Payments Pro”, “Virtual Terminal” and “PayPal Here” and UK merchants only:
• to report defaults and supply monthly account performance information, where the account shows an amount owing to us (reflected as a negative balance) for three or more consecutive months, to the databases of these third parties; and
• for the purposes set out in section 8 of this Privacy Policy.

Please note that data disclosed to these agencies and databases may be:
• retained by the applicable credit reference agency or database for audit and fraud prevention purposes;
• disclosed to other financial institutions for the purpose of gauging creditworthiness; and
• transferred outside of the EU and on a global basis.

Name, address, phone number, email address, date of birth, length of time at address, proof of identity, legal form, length of time in business, company registration number, VAT number, funding instrument including bank account and credit /debit card details (if appropriate), relevant transaction information (if appropriate), account balance, all information supplied and used for your application for the UK products “Website Payments Pro”, “Virtual Terminal” and “PayPal Here” and the financial instrument used to pay for your PayPal Here- enabled device.

 

CIFAS (UK) and the CIFAS database

For users with UK PayPal accounts only: to prevent and detect fraud (which may include checking details on job applicants and employees and on proposals and claims for all types of insurance).

Please note that data disclosed to this database may be:

• retained by the database for audit and fraud prevention purposes;
• disclosed to other financial institutions for the purpose of fraud prevention and detection
(including to prevent money laundering) for example, when checking details on applications for credit and other facilities, managing credit and credit related accounts or facilities, recovering debt, checking details on claims for insurance and checking details of job applicants or employees;

• used to determine your risk profile and for cooperation with the relevant authorities in compliance with the requirements of the Luxembourg Law of 5 April 1993 on the financial sector and laws relating to the prevention of money laundering, terrorism and fraud (excluding the treatment of personal data in relation to solvency of the persons referred to in article 14(1)(d) of the Luxembourg Law of 5 April 1993 on the financial sector); and
• transferred outside of the EU and on a global basis.

All account details and circumstances of the conduct of the account

 

Deltavista GmbH (Germany)

Establish risk associated with address, identity; assist in making decisions concerning a customer’s credit worthiness; research and testing as to appropriateness of new products and services.

Name, address, date of birth, email address

 

Accumio Finance Services GmbH (Germany), CEG Creditreform Boniversum GmbH (Germany), Bürgel Wirtschaftsinformationen GmbH & Co. KG (Germany)

To verify identity and address and retrieve contact phone numbers and addresses, establish risk associated with address, identity; research and testing as to appropriateness of new products and services.

To assist in making decisions concerning the credit worthiness of consumers (if they have a German PayPal account and have specifically consented to such check) and merchants, including without limitation, in relation to credit products offered by PayPal and offering direct debit payments as payment method.

The creditworthiness scores that we request from these agencies that include scores that are calculated according to mathematical-statistical procedures.

Please note the fact that PayPal requested such information, and any negative account performance data disclosed to these databases in relation to customers who have a German PayPal account may potentially be:

• retained by the database for audit purposes and for scoring of such customer’s creditworthiness;
• any such score may be disclosed to other third parties for the purpose of gauging creditworthiness.

and
• transferred outside of the EU and on a global basis.

Name, address, date of birth, email address, account status, account balance, and in case the transfer of such information is legally justified, also certain information on negative account performance of a customer with a German PayPal account, for which PayPal has requested a creditworthiness check from the respective database.

 

SCHUFA Holding AG (Germany), infoscore Consumer Data GmbH (Germany)

To verify a customer's identity and address, carry out checks for the prevention and detection of failing direct debit payments, and of crime including fraud and/or money laundering, including checks on the linkage of the customer and its bank account, to help determine creditworthiness of consumers (if they have a German PayPal account and have specifically consented to such check) and of merchants, and for research and testing as to appropriateness of new products and services.

The creditworthiness scores that we request from these agencies include scores that are calculated according to mathematical-statistical procedures.

Please note the fact that PayPal requested such information, and any negative account performance data disclosed to these databases in relation to customers who have a German PayPal account may potentially be:

• retained by the database for audit purposes and for scoring of such customer’s creditworthiness;
• any such score may be disclosed to other third parties for the purpose of gauging creditworthiness

and
• transferred outside of the EU and on a global basis.

Further, in relation to customers who have a German PayPal account, the information on a failed direct debit payment may be:

• retained by the infoscore database for audit purposes; and

• (without linkage to the customer’s identity) disclosed to other third parties for the purpose of preventing failed direct debit payments.

Name, address, email address, date of birth, gender, bank account details, information on failed direct debit payments from a bank account (without linkage to the identity of the customer), and in case the transfer of such information is legally justified, also certain information on negative account performance of a customer with a German PayPal account.

 

Creditreform Berlin Wolfram KG (Germany), Verband der Vereine Creditreform e.V. (Germany)

To determine creditworthiness of merchants.

Name, address, email-address.

 

World-Check (UK)

To verify identity.

All account information.

 

Global Data Corporation (USA)

To verify identity, carry out checks for the prevention and detection of crime including fraud, research and testing as to appropriateness of new products and services.

Name, address, date of birth, telephone number, email address

 

RSA Security Inc. (USA) and RSA Security Ireland Limited (Ireland)

To verify identity.

All account information.

 

ID Checker.nl BV (Netherlands) (Ireland)

To verify identity; research and testing as to appropriateness of new products and services.

Name, address, email address, date of birth, legal form, company registration number, VAT number, proof of identity, address, or other documents requested by PayPal and the data contained therein for Risk / Compliance purposes.

 

Aristotle International, Inc. (USA)

To verify identity.

Name, address, date of birth

 

Acxiom Ltd (UK), Acxiom Deutschland GmbH (Germany) and Acxiom France SAS (France)

To verify identity.

Name, address, phone number, email address and date of birth.

 

Creditinfo Decision (Czech Republic) and DecisionMetrics Limited (UK)

To assist with PayPal’s assessment of merchant risk.

All merchant account information.

 

Iovation Inc. (USA), ThreatMetrix Inc (USA)

To retrieve risk information regarding the IP and device from which you are accessing PayPal, research and testing as to appropriateness of new products and services.

IP and hardware information about the device (device ID)

 

TeleSign Corporation (USA)

To validate phone numbers, research and testing as to appropriateness of new products and services.

Telephone number

 

AddressDoctor GmbH (Germany),

To re-structure address data into normalized format.

Name, address, email address

 

Deutsche Post Direkt GmbH (Germany), AZ Direct GmbH (Germany), Deutsche Post Adress GmbH & Co. KG (Germany)

To validate and re-structure address data into normalized format and to verify name and address.

Name, address, email address

       
 

Mitek Systems Inc. (USA)

To validate images of identity documents and research and testing as to appropriateness of new products and services.

Proof of identity, details of bank accounts and credit/debit card information

 

Jumio Inc (USA)

To capture and validate proofs of identity and address

All data recorded on the customer’s identity and address documents

 

Au10tix Limited (Cyprus)

Automatic data extraction and document validation / forgery detection

Documents proving identity and address

 

Telovia SA (Luxembourg)

Identity validation and Know Your Customer (KYC) controls conducted for anti money laundering purposes

Name, address, date of birth, proof of ID and address

 

Syniverse Technologies, LLC (USA)

Validate and apply data quality checks to phone numbers (SMS message to be sent to the customer)

Name, address, phone number.

 

Signicat AS (Norway)

To verify and authenticate identity

Name, address, date of birth and e-id reference number

 

BankersAccuity Inc. (USA)

Research and testing as to appropriateness of new products and services in relation to the validation of the account data provided to us by the user and conversion of national account data information into IBAN

Customer’s bank account number and sort code and / or IBAN

 

ArkOwl LLC (USA)

To verify email address

Email address

 

Fraudscreen Ltd (UK)

To evaluate level of fraud risk

Name and address

 

LexisNexis (UK)

To assist with customer authentication

Name, address and date of birth

 

Trustev Ltd (Ireland)

To establish identity through customer’s social media data, connections and credentials

Name, address, date of birth, email address and account number

 

Tracesmart Ltd (UK)

To identify customers and assist with fraud detection, prevention, and or remediation of fraud, or other illegal actions or to detect, prevent or remediate violations of policies or the applicable user agreements.

Title, name, address, date of birth and telephone number

 

Zoot Enterprises, Inc. (USA)

To process technical applications and to provide a data and document gateway for account review and vetting purposes, and to exchange user information to contracted fraud and credit reference agencies. To also aggregate data from internal and external data sources and provide statistical analysis in order to assess the risk of fraud.

All account information and documents supplied by customers, to include information used to provide identity and address. This information may also include IP addresses.

 

First Data Corporation (USA)

To process merchant-initiated and customer-authorized transactions and to provide account/card processing services, to store transaction, payment and other customer data related to those transactions.

All account information and documents supplied by customers, to include information used to provide identity and address.

 

La Banque de France (France), GB Group plc (UK), SysperTec Communication (France)

Research and testing as to appropriateness of new products and services used to establish risk associated with address, identity, and associated with a customer’s credit worthiness.

Name, address, date of birth, phone number, email address

Financial Products

 

La Poste (France)

To resolve technical issues and user claims (when PayPal is being offered by the merchant through La Poste’s payment solution.

Any Account information necessary to resolve the issue or claim

 

Santander UK Cards Limited (UK)

To conduct joint marketing campaigns for PayPal Credit, and PayPal MasterCard, risk modelling, enforce terms and conditions for PayPal Credit and PayPal MasterCard.

Name, address, email address and account information (including, without limitation, account status).

 

TSYS Card Tech Limited (UK), TSYS Managed Services EMEA Limited (UK), PrePay Technologies Limited (trading as PrePay Solutions) (UK)

To conduct joint marketing campaigns for PayPal pre-paid card and risk and fraud modelling and to enforce terms and conditions for PayPal prepaid card.

Name, address, email address, date of birth and account information.

 

Société Générale (France), La Banque Postale (France), BNP Paribas (France) and Crédit Mutuel (France)

Billing purposes.

Only for merchants using PayPal through the partner’s payment solution: merchant ID, number of PayPal transactions, transaction volume with PayPal and, as the case may be, termination of the PayPal account.

 

Findomestic Banca (Italy), Cetelem S.A., Cofidis (France) and Cofinoga S.A. (France)

Registration of the credit card issued by the credit company on the user’s PayPal account and the processing of funding requests made by the same user.

Name, email address, date of birth (as the case may be), credit card number, expiry date, three digit Card Security Code (as the case may be) and amount of the funding request and any account information necessary for fraud or dispute resolution.

 

Total System Services, Inc. (USA)

To provide account/card processing services, call centre services, card printing, and statement printing services.

Name, address, email address, date of birth (as the case may be), credit card number; expiry date, three digit Card Security Code (as the case may be), amounts of funding requests, and any account information necessary for fraud or dispute resolution.

 

United Kapital Limited (UK) and United Kapital Limited, LLC (USA)

To enable you (or the merchant with which you transact) to use products issued by United Kapital with PayPal.

Only for PayPal merchants applying for and using products issued by United Kapital Limited: Name, business name, address, date of birth, copies of identification documents, PayPal identification (merchant ID), email address, phone number, transaction information (including, without limitation, number of PayPal transactions and transaction volume with PayPal), length of time as a PayPal user and, as the case may be, termination of the PayPal account.
For customers of those merchants: transaction information, name, email address, phone number, address and PayPal identification number.

Commercial Partnerships

 

Royal Mail Group Plc. (UK) and Pitney Bowes Inc. (USA)

To provide automated label printing for sellers using PayPal and eBay to facilitate postal and delivery services, including payment reconciliation services.

Name, address, email address and postage transaction amount.

 

Trustwave (USA)

To provide customised services and assistance to Merchants using PayPal, and to facilitate the process of becoming PCI DSS compliant.

Name, email address and PayPal account number.

Marketing and Public Relations

 

inContact (USA), Decipher Inc. (USA), Northstar Research Partners (USA)

To conduct customer service surveys.

Name, email address, type of account, type and nature of the PayPal services offered or used, and relevant transaction information.

 

Ipsos Mori UK Limited (UK), Ipsos GmbH (Germany), Ipsos SAS (France) and FactWorks GmbH (Germany)

To conduct customer service and marketing surveys.

Name, email address, phone number, type of account, type and nature of the PayPal services offered or used, and relevant transaction information.

 

Adwise (France) and Axance (France)

To conduct marketing surveys.

Name, email address, phone number, type of account, type and nature of the PayPal services offered or used, and relevant transaction information.

 

BD Network Limited (UK), Tullo Marshall Warren Limited (UK), and MyCash (France)

To develop and execute customer promotions.

Name, address and email address.

 

Salesforce.com, inc. (USA)

To store merchant contact information as well as other supporting information about the business relationship.

Name, address, phone number and email address, business name, URL PayPal Account ID and other supporting information about the business relationship, such as (without limitation) name of contact person and contact information at merchant and/or partner through which merchant has been onboarded, description of products sold through PayPal, communication notes and onboarding information, internal decisions about the merchant, revenue calculations and other information on the merchant’s business as made available by the merchant, and information relevant for special integrations of merchants, name and address of bank.

 

Daniel J Edelman Ltd (UK), Text 100 SARL (France), Text 100 (Spain) , Text 100 BV (Netherlands), Text 100 AB (Sweden), Text 100 Srl (Italy), Text 100 (Denmark) and I&E Consultants (France)

To answer media enquiries regarding customer queries.

Name, address, and all customer account information relevant to customer queries.

 

Alchemy Worx Ltd (UK)

To allow management reporting of marketing campaigns.

Name, email address and details of customer campaign interaction.

 

Carrenza Limited (UK)

To store user data for marketing campaigns.

Name, address, email address, business name, domain name, account status, account preferences, type and nature of the PayPal services offered or used, and relevant transaction information.

 

1000Mercis SA (France) and 1000Mercis Ltd (UK)

To store user data to conduct marketing campaigns on behalf of PayPal.

Name, email address, phone number, type of account, type and nature of the PayPal services offered or used, and relevant transaction information.

 

A McLay & Company Limited (UK), TNT Post Italia (Italy)

To assist in the execution of offline direct mail and marketing campaigns.

Name, address, email address, business name, domain name, account status, account preferences, type and nature of the PayPal services offered or used, and relevant transaction information.

 

Datacolor Dialog-Medien GmbH (Germany), MEILLERGHP GmbH (Germany) and W & J Linney Ltd (UK)

To assist in the execution of offline direct mail and marketing campaigns.

Name, email address, address, business name, domain name, account status, account preferences, type and nature of PayPal services offered or used.

 

Medallia, Inc. (USA)

To conduct customer service surveys.

Name, email address, type of account, type and nature of the PayPal services offered or used, and relevant transaction information.

 

Endlichsommer- werbung in bester gesellschaft mbh (Germany) and Crossover Communication GmbH (Germany)

To assist in the execution of offline direct mail and marketing campaigns

Name, address, business name, type and nature of PayPal services offered or used.

 

optivo GmbH (Germany)

To send emails; email marketing

Name of the merchant, name of the contact person, email address, address, status, client ID and shop system

 

Acxiom France SAS (France), Acxiom Ltd (UK) and Acxiom GmbH (Germany)

To collect additional user information and better target marketing campaigns.

Name, address, email address, date of birth and phone number.

 

Adelanto (France)

To execute marketing campaigns for merchants.

Name of the merchant, name of the contact person, address, email address, merchant website URL and type and nature of the PayPal Services offered or used.

 

Business support services - b2s, SAS (France)

To store merchants' contact information for marketing communications to those merchants.

Name of the merchant, name of the contact person, address, email address, phone number, merchant website URL.

 

Consultix (France and Spain) and Quadro Srl (Italy)

To host information provided by merchants and display part of this information on the pages of the PayPal website listing websites accepting PayPal and proposing special offers to PayPal users.

All information provided by merchants in connection with their use of these pages of the PayPal website (including in particular name of the merchant, name of the contact, email address, logo and information relating to the promotion(s) offered to PayPal users).

 

Criteo SA (France)

To execute retargeting campaigns in order to deliver personalised advertising.

Cookie ID

 

Mediaplex Inc. (USA)

To execute and measure retargeting campaigns in order to identify visitors and redirect them though personalised advertising campaigns.

PayPal Account ID (as appropriate) as well as device ID used by a specific person, content of advertisements to be delivered and segmentation in a user group for advertisement purposes.

 

Heaven SAS (France)

To execute marketing campaigns for merchants.

Name of merchant, merchant website URL, description of item purchased and price of item.

 

Tenthwave Digital, LLC (USA)

To notify winners and prize fulfillment for winners of survey sweepstakes

Name and email address, for sweepstakes winners and alternates only.

 

Sotiaf Telematiques Associes SAS (France)

To store user data for marketing campaigns and to execute direct marketing campaigns.

Name, email address, and phone number.

 

2engage (Germany) and Quo Vadis (Germany)

To conduct market surveys.

Name, company name, address, telephone number, domain name, e-mail address, type and nature of use of PayPal services, market segment and generalised categorisation of company size and information on participation in earlier surveys.

 

Facebook, Inc (USA) and Facebook Ireland Limited (Ireland)

To allow PayPal to facilitate the sharing by a PayPal user of transaction details that relate to a purchase made by that PayPal user with users of the Facebook platform (only when initiated by that PayPal user) and to implement failover carrier billing and to show Facebook users advertisements on Facebook.

Name of merchant, merchant website URL, description of item purchased and price of item; e-mail address associated with PayPal users (without indicating account relationship).

 

SurveyMonkey Spain, Sucursal em Portugal (Portugal) and SurveyMonkey.com, LLC (USA)

To assist in carrying out user surveys.

Name, email address and details of customer campaign interaction.

 

Marketing and Planning Systems, LLC. USA (USA), Dynamic Logic, Inc. (USA), GfK Custom Research LLC (USA), Millward Brown, Inc. (USA) and Radius Global Market Research, LLC (USA)

To conduct customer service and marketing surveys

Name, email address, type of account, type and nature of PayPal services offered or used, and relevant transaction information

 

Eloqua Limited (Canada)

To develop, measure and execute marketing campaigns.

Name, business name, address and registration number of merchant, name, job title, email address, phone number of merchant’s contact person, merchant website URL, PayPal account number, third party applications used by the merchant, behaviour on PayPal website.

 

Nanigans, Inc. (USA), Fiksu, Inc. (USA), Ad- X Limited (UK)

Help identify behaviour in the mobile app in order to guide decision about targeted marketing; to help efficiently handling and optimising mobile campaigns on social networks and elsewhere in the web

Device ID used by a specific person, events in the mobile app about the use of the mobile app by a specific user (including, without limitation, login, successful completion of the transaction), but no payment and financial information details.

Content of advertisements to be delivered to specific users and, as appropriate, segmentation group to which such person belongs to for advertisement purposes.

 

Zeuner S.p.A. (Italy), Accueil Srl (Italy) and CallCenterNet Italy s.r.l. (Italy)

To store merchants' contact information for marketing communications to those merchants.

Name of the merchant, name of the contact person, address, email address, phone number, merchant website URL.

 

Purepromoter Ltd t/a Pure360

To send service related and (depending on opt-in settings) promotional SMS messages to PayPal users.

Mobile Number

 

Pepper Global (Germany)

To execute marketing campaigns for existing merchants and prospects

Mobile Number

Operational services

 

Dr. Frankenheim & Partner Lawyers (Germany, Austria), NCO Europe Limited (UK), Robinson Way Limited (UK), Intrum Justitia Limited (UK), IQOR Recovery Services Limited (UK), Capita Plc (UK), Compagnie Francaise du Recouvrement (France), EOS Solutions UK Plc (UK), Transcom Worldwide S.A. (UK), Transcom Worldwide (UK) Limited (UK), Newman & Company Limited (UK), Clarity Credit Management Solutions Limited (UK), eBay Europe Services SARL (Luxembourg); EOS Solution Deutschland GmbH (Germany), EOS Aremas Belgium SA/NV (Belgium), EOS Nederland B.V. (Netherlands), Arvato Infoscore GmbH (Germany), Arvato Services Iberia (Spain), Infoscore Iberia (Spain), Transcom WorldWide (France), SAS (France) Transcom WorldWide S.p.A. (Italy)

To collect debt.

Name, address, phone number, account number, date of birth, email address, account type, account status, last four digits of financial instruments account, sort code, account balance, details of account transactions and liabilities, and name of funding source provider.

 

KSP Kanzlei Dr. Seegers (Germany), BFS Risk & Collection GmbH (Germany); HFG Hanseatische Inkasso- und Factoring-Gesellschaft (Germany)

To collect debt; to handle reporting to credit reference agencies about defaulting customers.

Name, address, phone number, account number, date of birth, email address, account type, account status, last four digits of financial instruments account, sort code, account balance, details of account transactions and liabilities, name of funding source provider, applicable details of account behaviour and correspondence relevant for reporting to credit reference agencies.

 

Begbies Traynor Group plc (UK), Moore Stephens LLP (UK)

To collect debt from insolvent customers

Name, address, phone number, account number, date of birth, email address, account type, account status, last four digits of financial instruments account, sort code, account balance, details of account transactions and liabilities, and name of funding source provider.

 

Webbank (USA)

Only for customers who are also customers of Bill Me Later, Inc.: to help with accounting and recovery services

Name, address, phone number, account number, date of birth, email address, account type, account status, last four digits of financial instruments account, sort code, account balance, details of account transactions and liabilities, and name of funding source provider.

 

Digital River Inc. (USA) and Research in Motion Limited (USA)

To enable you to access and use PayPal via a mobile device (for example mobile phone or PDA).

Applicable details of your account information which are transmitted as part of your use of PayPal via a mobile device.

 

mediafinanz AG (Germany)

To collect debt, to request and proceed information from and to Schufa, Buergel and other credit reference and fraud agencies for PayPal

Name, address, phone number, account number, date of birth, business name, email address, account type, account status, last four digits of financial instruments account, account balance, details of account transactions and liabilities, name of funding source provider, credit score received from agency, account performance data

 

Zyklop Inkasso Deutschland GmbH (Germany), PNO inkasso AG (Germany)

To collect and manage debt, to support collections teams in case of insolvent customers

Name, address, phone number, account number, email address, account type, account status, last four digits of financial instruments account, sort code and name of funding source provider, account balance, date and amount of last payment, results of creditworthiness checks

 

Informa Solutions GmbH (Germany)

To request and proceed information from and to Schufa, Buergel and other credit reference and fraud agencies in and from and to ID Checker

Name, date of birth business name, legal form, address, email address, company registration number and VAT number.

For the purpose of verification of identity also: other information contained in documents requested by PayPal for Risk / Compliance purposes.

For customers with a German PayPal account also: phone number, length of time at address, length of time in business, length of time with PayPal, funding instrument including bank account and credit /debit card details and relevant transaction information, credit score received on behalf of PayPal from a credit reference agency, account number, account type, account status, account balance, details of account transactions and liabilities, negative account performance data.

 

P K Consultancy Limited (UK)

To assess risk and help detect and prevent potentially illegal acts and violations of policies.

Name, address, phone number, account number, email address, account type, last four digits of financial instruments account, account balance, details of account transactions and liabilities, account status and account performance information as required for the Purpose

 

Robertson Taylor Insurance Brokers Limited (UK)

Consultation with respect to risk assessment of specific merchants and merchant transactions

Name, address, phone number, account number, business contact details, domain name, email address, account type, account balance, details of account transactions and liabilities, account status and account performance information as required for the Purpose.

 

Yesmail Inc. (USA), Responsys (USA), Silverpop Systems Inc. (USA) and e-Dialog, Inc. (USA)

To fulfil email operations in respect of the PayPal services (including, but not limited to, operations, customer services, collections, marketing programmes and promotions).

Name, address, email address, business name, business contact details, domain name, account status, account type, account preferences, type and nature of the PayPal services offered or used and relevant transaction and account information.

 

Blue Media S.A. (Poland)

To verify identity and ensure that a user is a PayPal account holder. To process instant funding requests made by a user through the Blue Media services.

Name and email address.

 

Consultix GmbH (Germany)

To assist in the creation of PayPal Business Accounts for merchants on-boarding through their bank's or other contract partner payment or service gateway.

All information provided by the merchant (directly or via his/her bank or other contract partner) for the purpose of creating his/her PayPal business account (including without limitation email address, address, business name, business contact details and bank account details).

 

Akami Technologies Inc. (USA)

Content delivery network – to deliver PayPal page content from local servers to users.

User IP address and cookies.

 

azionare GmbH (Germany)

To distribute prizes in prize promotions on Facebook.

Name, email address.

 

ITELLIUM mobile Solutions GmbH (Germany); CartaSi S.p.A - Gruppo ICBPI (Italy)

To assist in the production of innovative payment methods (e.g. applications) and processing of payments through such innovative payment methods.

All account information.

 

Trustwave Holdings Inc. (USA)

To provide PCI compliance validation services for merchant accounts and merchant integrations.

Business name, address, account number, merchant type, compliance program used, PCI Level, PCI Status, PCI Expiry, name, email address, phone number of merchant’s contact person

 

Zoot Enterprises, Inc. (USA)

To process technical applications and to provide a data and document gateway for account review and vetting purposes, and to exchange user information to contracted fraud and credit reference agencies.

All account information and documents supplied by customers such as proofs of identity and address

 

RR Donnelley and Sons Company (USA)

To provide printing services such as statements and other printed materials

Name, address, email address, and account information

 

Scorex (UK) Limited (UK)

To provide a technology solution to allow PayPal to process, send and receive credit information of users via its contracted credit reference agencies.

Name, address, email address, date of birth, length of time at address, phone number, legal form, length of time in business, company registration number, VAT number (if appropriate).

 

OXID eSales AG (Germany)

Services in connection with the development and operation of a payment system for stationary trade (point of sale)

All account information and transaction information (as appropriate).

 

Ordermotion, Inc. (USA)

To collect data and create/deliver (direct to customer) orders for the PayPal Here product (including, without limitation, the PayPal Here-enabled device).

Name, address, email, phone number, credit card information and PayPal Payer ID.

 

Ingram Micro, Inc. (USA) and Ingram Micro (UK) Limited (UK)

To act as PayPal's fulfilment distributor for the PayPal Here product (including, without limitation, the PayPal Here-enabled device).

Name and address.

Group companies

 

PayPal Inc. (USA)

Acting on behalf of PayPal for the purposes of storing and processing of account information.

All account information.

 

PayPal Europe Services Limited (Ireland), eBay Europe Services Limited (Ireland), PayPal Malaysia Services Sdn Bhd (Kuala Lumpur), PayPal Israel Ltd (Israel), PayPal India Private Limited (India), PayPal (UK) Ltd (UK), PayPal France S.A.S. (France), PayPal Deutschland GmbH (Germany), PayPal Spain SL (Spain), PayPal Italia Srl (Italy), PayPal Nederland BV (Netherlands), PayPal European Marketing SA (Switzerland), PayPal Polska Sp Zoo (Poland), PayPal Bilisim Hizmetleri Limited Sirketi (Turkey), PayPal International Sarl (Luxembourg) and PayPal SE (UK)

Acting on behalf of PayPal for the purpose of customer support, risk assessment, compliance and/or other back office.

All account information.

 

PayPal Pte. Ltd. (Singapore)

Acting for the account of PayPal by entering into and performing non-customer contracts which involve customer data.

All account information.

 

eBay Inc. (USA), eBay Europe S.à r.l. (Luxembourg),eBay Services S. à r.l. (Luxembourg), eBay International AG (Switzerland), eBay Corporate Services GmbH (Germany), eBay France SAS (France), eBay (UK) Limited (UK), eBay CS Vancouver Inc. (Canada), eBay Partner Network Inc. (USA), eBay Internet Support (Shanghai) Co Ltd (China), eBay Enterprise Marketing Solutions (USA) (formerly GSI Commerce, Inc (USA), VendorNet Inc (USA), PepperJam Network (USA), FetchBack (USA), GSI Media Inc. (USA), e-Dialog, Inc. (USA), M3 Mobile Co., Ltd. (Korea), MBS (USA), ClearSaleing (USA), True Action Network (USA), True Action Studio (USA)),GumTree.com Limited (UK), Kijiji International Limited (Ireland), Kijiji US Inc. (USA), mobile.de & eBay Motors GmbH (Germany), Shopping.com Inc. (USA), Shopping Epinions International Limited (Ireland), PayPal Australia Pty Limited (Australia), Marktplaats B.V. (Netherlands), PayPal Charitable Giving Fund (USA), PayPal Giving Fund UK (UK), Tradera AB (Sweden), StubHub, Inc. (USA), Viva Group, Inc. (USA), StubHub Europe S.à r.l. (Luxembourg), StubHub Services S.à r.l. (Luxembourg), Viva Group, Inc. (USA), ProStores Inc. (USA), MicroPlace, Inc. (USA), Internet Auction Co., Ltd. (Korea), Via-Online GmbH (Germany), Bill Me Later, Inc. (USA), Zong Inc.(USA) and X.commerce, Inc. (USA).

To provide joint customers content and services (including, but not limited to registration, transactions, failover for carrier billing accounts, and customer support), to assess risk, or to help detect, prevent and/or remediate fraud, or other potentially illegal acts and violations of policies, and to guide decisions about their products, services and communications.

All account information.

Agencies

 

CSSF (Luxembourg), CNPD (Luxembourg), Financial Ombudsman Service (UK), Altroconsumo (Italy), European Consumer Centre Network organisations (located in Austria, Belgium, Bulgaria Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the UK), Les Mediateurs du Net (France), Risolvi Online (Italy) and BaFin (Germany)

To provide the Agencies listed with information within their authority (upon their request) and to respond to queries and/or investigations instigated by users or other stakeholders in the countries where they have jurisdiction.

All account information

  1. For the purpose of this table, the phrase "All account information" includes: name, address, email address, phone number, IP address, machine ID, mobile phone ID and/or number, account number, account type, details of funding instruments associated with the account, details of payment transactions, details of commercial transactions, customer statements and reports, account preferences, details of identity collected as part of our "know your customer" checks on you, and customer correspondence.

  2. With respect to the column titled, "Purpose", each third party, with the exception of the regulatory agencies, certain of the payment processors and credit reference and fraud agencies and group companies referred to at the end of this table, is carrying out the purpose to fulfil obligations which PayPal has contracted with the entity to fulfil. The regulatory agencies are carrying out their purpose in accordance with their regulatory objectives and requirements. Where explicitly specified in the table, the payment processors and credit reference and fraud agencies may use the information in their respective databases, and forward information to third parties for the purposes of fraud prevention and the assessment of creditworthiness, in accordance with their respective terms.

  3. Disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
  4. Disclose aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in Manchester. However, this aggregated information is not tied to personal information.

    As with any other business, it is possible that in the future PayPal could merge with, or be acquired by, another company. If such an acquisition occurs, you consent to the successor company having access to the information maintained by PayPal, including customer account information, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.

Our Contact with PayPal Customers

We communicate with our users on a regular basis via email to provide requested services. We also communicate with our users by phone to:

  • resolve customer complaints or claims made by users via the PayPal Services;
  • respond to requests for customer service;
  • inform users if we believe their accounts or any of their transactions have been used for an illegitimate purpose;
  • confirm information concerning a user's identity, business or account activity;
  • carry out collection activities;
  • conduct customer surveys; and
  • investigate suspicious transactions.

We use your email or physical address to confirm your opening of a PayPal account, to send you notice of payments that you send or receive through PayPal (including referral payments described below), to send you information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.

We also use your email address to send you other types of communications that you can control, including "News from PayPal", auction tips, customer surveys and notice of special third-party promotions. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the PayPal website, selecting My Account, Profile, then My account settings, and updating your Communication preferences.

We may communicate with you as described above by SMS (and SMS will be treated as an email for the purpose of managing your Communication preferences).

In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

Your Use of Information and Our Services

In order to facilitate the transactions between PayPal users, our service allows you limited access other users' contact or delivery information. As a seller you may have access to the User ID, email address and other contact or delivery information of the buyer, and as a buyer you may have access to the User ID, email address and other contact information of the seller.

You agree that, with respect to other users' personally identifiable information that you obtain through the PayPal Services or through a PayPal-related communication or PayPal-facilitated transaction, you will only use this information for: (a) PayPal-related communications that are not unsolicited commercial messages, (b) ancillary actions in relation to the PayPal payments or the transactions for which PayPal has been used (e.g. insurance, delivery and fraud complaints), and (c) any other purpose that such user consents to after adequate disclosure of the purpose(s).

In all cases, you must provide users with the opportunity to remove their data from your database and review any information you have collected about them. More generally, you must comply with all applicable privacy regulations, in particular as they relate to the sending of marketing emails.

PayPal does not tolerate spam. We strictly enforce our Anti-Spam Policy. To report PayPal-related spam to PayPal, please contact us.

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5. Information Security

PayPal is committed to handling your customer information with high standards of information security. 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 fulfil their job responsibilities.

For more information on PayPal's security practices, please see our Safety Advice.

The security of your PayPal account also relies on your protection of your PayPal password. You may not share your PayPal password with anyone. PayPal representatives will never ask you for your password, so any email or other communication requesting your password should be treated as unauthorised and suspicious and forwarded to spoof@paypal.com. If you do share your PayPal password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings, and also contact us right away.

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6. Accessing and Changing Your Information

You can review the personal information you have provided us and make any desired changes to such information, or to the settings for your PayPal account, at any time by logging in to your account on the PayPal website, selecting My Account, then Profile and changing your preferences. You can also close your account through the PayPal website. If you close your PayPal account, we will mark your account in our database as "Closed", but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.

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7. Accountability

Our privacy office is responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you want to exercise your right to access your information or have any questions about this privacy statement, PayPal's information practices, or your dealings with PayPal, you can contact us by using this form, or by calling the customer service number located on our website, or by writing to us at PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg.

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8. IMPORTANT DATA PROTECTION INFORMATION FOR USERS RECEIVING PAYMENTS THROUGH WEBSITE PAYMENTS PRO (INCLUDING VIRTUAL TERMINAL) AND/OR PAYPAL HERE*

* PayPal Here is PayPal POS Functionality within the PayPal Mobile App (as defined in our User Agreement) that enables a User to pay another User (typically a merchant) or anybody to make a direct card payment to that merchant, in each case for goods and services at a physical point of sale (for example, in store). 

A GUIDE TO THE USE OF YOUR PERSONAL DATA BY PAYPAL (EUROPE) S.À.R.L. ET CIE, S.C.A. AND CREDIT REFERENCE AGENCIES

SECTION 1: GENERAL INFORMATION ON OUR USE OF CREDIT REFERENCE AGENCIES

Q: What is a credit reference agency?

A: Credit reference agencies (CRAs) collect and maintain information on consumers' and businesses' credit behaviour, on behalf of financial institutions and lenders in the UK.

Q: Why do you use them when I have applied to your organisation?

A: Although you have applied to us, PayPal (Europe) S.à.r.l. et Cie, S.C.A. and we will check our own records, we may also contact CRAs to get information on your, your financial and/or business associates’ and your business’ credit behaviour with other organisations. This will help us make the best possible assessment of your overall situation before we make a decision.

Q: Where do they get the information?

A: From publicly available sources, including:

- electoral registers maintained by local authorities;
- County Court Judgments records operated by Registry Trust Limited;
- bankruptcy information held by the Insolvency Service; and
- fraud information from fraud prevention agencies. 

Credit information also comes from information on applications to banks, building societies, credit card companies etc and also from the conduct of those accounts.

Q: How will I know if my information is to be sent to a CRA or fraud prevention agency?

A: Organisations are only allowed to send information to CRAs and/or fraud prevention agencies with your agreement and knowledge. You will be told when you apply for Website Payments Pro or PayPal Here if your data will be supplied. The next section of this document will tell you how, when and why we search information at CRAs and what we do with the information we obtain from them. We will also tell you if we plan to send information on you or your business, if you have one, to CRAs.

Q: Why is my data used in this way?

A: We and other organisations want to make the best possible decisions we can, in order to make sure that you, or your business, will be able to carry out your obligations to us. We and other organisations may also use the information to check your identity. In this way we can ensure that we all make responsible decisions. At the same time we also want to make decisions quickly and easily and, by using up-to-date information, provided electronically, we are able to make the most reliable and fair decisions possible.

Q: Who controls what credit reference agencies are allowed to do with my data?

A: All organisations that collect and process personal data are regulated by the Data Protection Act 1998, overseen by the Office of the Information Commissioner. All credit reference agencies are in regular dialogue with the Commissioner. Use of the Electoral Register is controlled under the Representation of the People Act 2000.

Q: Can just anyone look at my data held at credit reference agencies?

A: No, access to your information is very strictly controlled and only those that are entitled to do so may see it. Usually that will only be with your agreement or (very occasionally) if there is a legal requirement.

SECTION 2: WHAT PAYPAL (EUROPE) S.À.R.L. ET CIE, S.C.A. DOES

Please read this section very carefully.

  1. When you apply to us for Website Payments Pro or PayPal Here we may:
    1. Check our own records for information on your PayPal account(s).
    2. Search at credit reference agencies for:
      1. public data on your credit behaviour;
      2. information on the conduct of your personal credit accounts if you are proprietors of a small business; and 
      3. information on your business accounts.
    3. Search at fraud prevention agencies for information on you
  2. What we do with the information you supply to us as part of the application:
    1. Information that is supplied to us will be sent to credit reference agencies.
    2. If you give us false or inaccurate information and we suspect fraud, we will record this and may also pass this information to financial and other organisations involved in fraud prevention to protect us, them and our respective customers from theft and fraud.
    3. Your data may also be used by PayPal, to offer your business other products.
  3. With the information that we obtain we will:
    1. Assess your application for Website Payments Pro or PayPal Here;
    2. Verify your identity and the identity of other directors/partners;
    3. Undertake checks for the prevention and detection of fraud and/or money laundering;
    4. Possibly use scoring methods to assess this application and to verify your identity;
    5. Manage your PayPal account(s) with ourselves; and/or
    6. Undertake periodic statistical analysis or testing to ensure the accuracy of existing and future products and services.
    7. Any or all of these processes may be automated.
  4. What we do when you have set up Website Payments Pro or PayPal Here:
    1. Where you have access to and use Website Payments Pro or PayPal Here, we will give details of your PayPal account and other details of your use of Website Payments Pro or PayPal Here (as the case may be), including names and parties to the account, and how you manage it to credit reference agencies.
    2. If you owe us money and do not pay in full and on time, we will tell credit reference agencies.
    3. We may make periodic searches of our own group records, credit reference and fraud prevention agencies to manage your account with us, to take decisions regarding your identity and also credit, including whether to make Website Payments Pro or PayPal Here (as the case may be) available or to continue or extend existing services to you.
    4. If you owe us money and do not make payments that you owe us, we will trace your whereabouts and recover payment.

SECTION 3: WHAT CREDIT REFERENCE AGENCIES DO

  1. When credit reference agencies receive a search from us they will:
    1. Place a search "footprint" on you and/or your business' credit file whether or not this application proceeds. If the search was for a credit application the record of that search (but not the name of the organisation that carried it out) may be seen by other organisations when you apply for credit in the future.
    2. Link together the previous and subsequent names advised by you, of anyone that is a party to the account.
  2. Supply to us:
    1. Information about you and/or your business or credit information such as previous applications for credit and the conduct of the accounts;
    2. Public information, such as details of County Court Judgments (CCJs) and bankruptcies;
    3. Electoral register information on you and your business partners; and/or
    4. Fraud prevention information.
  3. When information is supplied by us, to them, on your account(s):
    1. Credit reference agencies will record the details that are supplied on your account including previous and subsequent names of the parties
    2. If you owe us money and do not pay in full and on time, credit reference agencies will record the outstanding debt.
    3. Records shared with credit reference agencies remain on file for six years after they are closed whether settled by you or defaulted.
  4. How your data WILL NOT be used by credit reference agencies:
    1. It will not be used to create a blacklist.
    2. It will not be used by the credit reference agency to make a decision.
  5. How your data WILL be used by credit reference agencies:
    1. The information which we, other organisations and fraud prevention agencies provide to the credit reference agencies about you, your financial and/or business associates and your business may be supplied by credit reference agencies to other organisations and used by them to:

      1. Verify your identity if you or your financial or business associate applies for other facilities including all types of insurance applications and claims.
      2. Assist other organisations to make decisions on credit, credit related services and on motor, household, life and other insurance proposals and insurance claims, about you, your partner, other members of your household or your business.
      3. Trace your whereabouts and recover payment if you do not make payments that you owe.
      4. Conduct checks for the prevention and detection of crime including fraud and/or money laundering.
      5. Manage your personal, your partner’s and/or business account
      6. Manage your personal, your partner’s and/or business insurance policies (if you have one/any).
      7. Undertake statistical analysis and system testing.
    2. Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
    3. Your data may also be used to offer you other products, but only if you have not opted out of receiving such offers. 

How to Find Out More

You can contact credit reference agencies currently operating in the UK (the main ones are listed below). The information they hold may not be the same so it is worth contacting them all. They will charge a small statutory fee.

CallCredit Ltd., Consumer Services Team, PO Box 491, Leeds, LS3 1WZ
0870 0601 414 (UK)
www.callcredit.co.uk

Experian, CreditExpert, PO Box 7710, Nottingham, NG80 7WE
0870 2416 212 (UK)
www.experian.co.uk

Equifax Plc, Credit File Advice Centre, PO Box 1140, Bradford, BD1 5US
0870 0100 583 (UK)
www.equifax.co.uk

Dun & Bradstreet Ltd, Customer Service Department, Marlow International, Parkway, Marlow, Bucks, SL7
1AJ
0845 145 1700 (UK)
http://www.dnb.co.uk

If you want to receive details of those fraud prevention agencies from whom we obtain and with whom we record information about you, write to us at PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg. You have a legal right to these details.