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Policy Updates

 

This page informs users in advance of important changes to the PayPal service, its User Agreement, or other policies. This page displays policy updates with future effective dates. Go to “Past Policy Updates” for previous policy updates.

 

Amendment to the PayPal User Agreement

Effective Date: Jun 17, 2014

 

Please read this document.

You do not need to do anything to accept the changes as they will automatically come into effect on the above date. Should you decide you do not wish to accept them you can notify us before the above date to close your account (https://www.paypal.com/it/cgi-bin/?&cmd=_close-account) immediately without incurring any additional charges.

We do hope, however, that you continue to use PayPal and enjoy the following benefits:

It’s safer

When you pay with PayPal your financial details are never shared with sellers or retailers, so you’re more protected against fraud.

It’s faster

You don’t have to type in your card details each time you pay, so you can check out faster online. You can also get eBay items delivered more quickly, as you can pay the seller instantly.

It’s easier

PayPal is the preferred web payment method in Italy because it’s a smarter, savvier way to pay online in just a few clicks. All you need is your email address and a password.

Please review the current User Agreement.

Amendment to the PayPal User Agreement.

  1. PayPal as Login Method

    PayPal allows certain third parties, with your permission, to use PayPal as a means for you to log into those third parties’ websites or other online services.  A new section 2.4 has been added to explain how this works and clarify your rights and the obligations of the party offering PayPal as a means of login, which reads as follows:

    “2.4 PayPal as Login Method. If you use PayPal as means of logging into external websites or mobile apps, we may share your login status with any third party offering this Service as a login method, as well as the personal and other Account information that you consent to being shared so that the third party can recognise you. PayPal will not give such third party access to your PayPal Account and will only make payments from your Account to that third party with your specific authorisation.

    If you offer this Service as a means for visitors to log into your website, app, or otherwise for your customer accounts, you must agree to any specific terms applicable when this functionality is made available to you, and comply with any specifications in any integration manual or guideline. PayPal does not guarantee or otherwise represent the identity of any user of this login method. PayPal will not share with you the personal and other Account information of the user (including login status) held by PayPal unless the user has consented to our disclosure of that information to you.”

  2. Funding Sources

    Section 3.4 is amended by the insertion of:

    1. a new paragraph clarifying that, when adding a card as a Funding Source, you are providing PayPal with a continuous authority to automatically charge that card as a Funding Source; and
    2. a new paragraph outlining how special Funding Sources (such as merchant specific balances and gift vouchers) may be used

    The new paragraphs read as follows:

    “Cards as Funding Sources:By adding a debit card, credit card or pre-paid card as a Funding Source, you are providing PayPal with a continuous authority to automatically charge that card to obtain the relevant funds when the card is used as a Funding Source pursuant to this Agreement.  You can stop the continuous authority in respect of any card by removing that card as a Funding Source in your Account Profile.

    Special Funding Sources: Certain payments may be funded by special Funding Sources linked to your Account, such as merchant specific balance, gift vouchers or other promotional funding sources, the use and priority of which are subject to further terms and conditions between you and PayPal (“Special Funding Sources”).  Your Account Overview may show, as part of your overall account balance, the notional amount available in your Special Funding Sources to fund qualifying payments at any given time.”

  3. Preferred Funding Sources when making Recurring or Automatic Payments

    Section 3.5b is amended to clarify how you may use a Preferred Funding Source for Recurring or Automatic Payments.  The amended section 3.5b now reads as follows:

    “3.5 Preferred Funding Source. If you would like to select a Preferred Funding Source, you may do so in these instances

    (…)

    1. In your Account Profile - Recurring Payments. If you have set up a Recurring or Automatic Payment, or authorized a merchant or other third party to collect payments from your PayPal Account, you may be able to select a Preferred Funding Source for all future payments to the merchant or other third party. You may do so by logging in to your Account, selecting "Profile'", selecting "Recurring Payments" or "Pay List", and then by selecting the links to set a Preferred Funding Source (may be called "Backup Funding Source"). Otherwise we will use your Default Funding Source.”

    ...

  4. Third party initiated payments (including Recurring Payments).

    The paragraph in section 3.10 (Third party initiated payments (including Recurring Payments)) setting out obligations on payment recipients to notify the payer in advance is amended to read as follows:

    “3.10 Third party initiated payments (including Recurring Payments). A third party initiated payment is a payment made on the basis of your advance Authorisation to a third party (for example, a merchant, or a mobile app provided by a merchant, or eBay) to collect funds from your PayPal Account.”

    We have added a paragraph in Section 3.10  to outline what happens when you make a payment to a merchant through the PayPal Location Based Payments Functionality of the PayPal Mobile App. The additional paragraph reads as follows:

    “If you use the PayPal Location Based Payments Functionality to make a Third Party Initiated Payment to another User (typically a merchant) who accepts payments through the PayPal Location Based Payments Functionality, you may Authorise that User by selecting the User in the PayPal Location Based Payments Functionality.   When you Authorise such a User, we may restrict the total amount that the Authorised User can request from your Account within a specific time period, as we may determine at our own discretion.”

  5. Canceling Recurring Payments

    We have added a paragraph in Section 3.11 to outline how an Authorisation made for a payment using the PayPal Location Based Payments Functionality of the PayPal Mobile App can be cancelled. The additional paragraph reads as follows:

    "When you use the PayPal Location Based Payments Functionality to give an Authorisation for a Third Party Initiated Payment to a User (typically a merchant) who accepts payments through the PayPal Location Based Payments Functionality, you may only cancel the Authorisation by following the steps to cancel your selection of the User in the PayPal Location Based Payments Functionality.”

  6. Receiving Money

    We are adding a short sentence to the start of section 4 to clarify the possibilities of receiving money with PayPal, which reads as follows:

    PayPal may allow anybody (with or without a PayPal Account) to initiate a payment to your Account.”

  7. Restricted Activities

    A new Section 9.1. ah is added to make it a restricted activity to fail to comply with mandatory requirements set out in our integration or programmers’ guides. The new section 9.1. ah reads as follows (presented in context with its root clause):

    9.1 Restricted Activities. In connection with your use of our website, your Account, or the Services, or in the course of your interactions with PayPal, a User or a third party, you will not:

    (…)

    ah. Integrate or use any of the Services without fully complying with all mandatory requirements communicated to you by way of any integration or programmers’ guide or other documentation issued by PayPal from time to time.”

  8. Keeping your Payment Instrument Safe

    Section 9.2 is amended by the addition of new sub-sections 9.2.i and 9.2.j, which, in general, require you to keep your personal details in your Account up to date and take all reasonable steps to protect the security of any device that you use to access the Services. The new sections 9.2.i a and 9.2.j read as follows (presented in context with their root clauses):

    You agree to perform the following actions to keep your Payment Instrument safe:

    (…)

    i. Keep your personal details in your Account up to date. We may be unable to respond to you if you contact us about your Account from an address, telephone number or email account that is not registered with us.

    j. Take all reasonable steps to protect the security of the personal electronic device through which you access the Services (including, without limitation, using pin and/or password protected personally configured device functionality to access the Services and not sharing your device with other people).”

  9. PayPal Buyer Protection

    We have added a new Section 13.3.c. to outline how items paid for using certain PayPal point of sale functionality may be covered by PayPal Buyer Protection. The new Section 13.3.c. reads as follows:

    “c. PayPal POS Functionality

    i. If you use any PayPal POS Functionality (including the PayPal Location Based Payments Functionality ) in person at a physical point of sale (for example, in store) to pay (or agree to be invoiced f or a payment) from your PayPal Account for your item (such item being a “POS Item”), we recommend that you inspect the POS Item in the presence of the Payment Recipient at the physical point of sale wherever possible, so that you can deal immediately and directly with the Payment Recipient if any issues arise with the POS Item.

    ii. You may open a Dispute alleging that a POS Item is Significantly Not as Described, only if:

    a. the POS Item was not made available to you for inspection immediately before you took physical possession of it (for instance, you took physical possession of the POS Item when it was in its original intact and non-re-sealable packaging); and

    b. the POS Item’s condition as Significantly Not as Described only became apparent to you when you took physical possession of the item (for instance, you only discovered that the POS Item was Significantly Not as Described when opening the packaging for the first time at home).

    iii. You may open a Dispute alleging that a POS Item is (and we may treat your POS Item as) an INR, only if:

    a. you agreed in writing with the Payment Recipient to receive the POS Item at a time and/or place other than the physical point of sale; and

    b. the Payment Recipient did not make the POS Item available to you as agreed.”

    Section 13.7 is added to clarify the extent of your potential liability under PayPal Buyer Protection if you are a Payment Recipient (i.e. a seller). new section 13.7 reads as follows:

    “13.7 Scope of coverage

    Payment Recipients: As a Payment Recipient you are liable to PayPal if you lose a Claim from a buyer with a PayPal account registered anywhere in the world (whether under the PayPal Buyer Protection policy of the country of registration of that buyer’s PayPal Account or otherwise). This includes, without limitation, where you sell to a buyer who is a Full Programme User and the buyer files a SNAD Claim, in which case you will generally be required to accept the item back and refund the buyer the full purchase price plus original shipping costs. You will not receive a refund on your PayPal fees. If you lose a Significantly Not as Described Claim because the item you sold is counterfeit, you will be required to provide a full refund to the buyer and you will not receive the item back (it will be destroyed). If you sell or market to buyers in other countries, please read the PayPal Buyer Protection policy of the countries in which your target buyers are based (accessible via the “Legal” or “Legal Agreements” footer on most PayPal site pages) as these policies will apply to you as a Payment Recipient or seller.

    The first paragraph of Section 13.9.a (What is Significantly Not as Described (SNAD)?) is also amended to clarify the definition of “Significantly Not as Described”. The amended relevant paragraph of Section 13.9.a now reads as follows:

    “An item is Significantly Not as Described if it is materially different from the last description of the item that you received from the Payment Recipient before you paid for the item (which, for exclusively online purchases, shall be taken to be the Payment Recipient’s description of the item in the item listing). Here are some non-exhaustive examples:

    …”

  10. Event Tickets

    A new Section 13.13 is added to give buyers notice that in certain cases the proceeds of their payments to Payment Recipients for event tickets may be held on trust for (i.e. for the benefit of) the buyer, to ensure that they can get their money back through PayPal, subject to further conditions, if the event does not take place on the scheduled date: The new section 13.13 reads as follows:

    13.13 Event tickets

    In certain cases, if you purchase a ticket or pay for the right to attend an event from a Payment Recipient who is a UK registered PayPal Account holder (“Event”), all monies paid by you will be held by PayPal on trust for you, so that the beneficial interest in such monies remains with you until the performance of the Event in question.”  

  11. Definitions

    Section 15 is amended to include the following new or amended terms and their definitions:

    aj. “PayPal Location Based Payments Functionality” means the PayPal POS Functionality within the PayPal Mobile App that enables a User to pay another User (typically a merchant) for goods and services at a physical point of sale (for example, in store), by which the paying User selects and thereby Authorises the other User (i.e. the merchant) to receive a payment.

    ak. “PayPal Mobile App” means the application on a mobile device that enables a User to carry out certain PayPal Account transactions using that mobile device.

    al. PayPal POS Functionality” means any functionality provided by PayPal used exclusively at a physical point of sale that enables a User to receive payment for goods and services in that User’s PayPal account.

    aw. POS Item” has the meaning given in section 13.3.c.

    ax. Reversal” means a payment that you received which PayPal may reverse to the sender or another third party because the payment: (a) has been challenged by a buyer directly with their bank; and/or (b) removed from your Balance for any reason (other than a Chargeback or Claim pursuant to PayPal Buyer Protection), including, without limitation, where(i) the payment violates our Acceptable Use Policy, or we reasonably suspect that the payment violates our Acceptable Use Policy or (ii) the payment amount was not authorized by the sender with the relevant third party in connection with a valid third party initiated payment authorization (see section 3.10); or (iii) the payment was funded by a bank transfer that was subsequently reversed by the bank for any reason and/or (c) has been categorised by PayPal’s internal risk modelling as a risky payment required to be reversed to mitigate the risk associated with the payment. The term “Reversed” shall be construed accordingly.”

  12. Personal Transactions

    Note c. at the definition of “Personal Transaction” in Schedule 1 – Table of Fees is amended to reflect the fee payment options available to senders and recipients of Personal Transactions (with the sender paying the processing fee for a Personal Transaction by default, subject to certain exceptions). Corresponding changes have been made to text in the table fees for Cross Border Personal Transactions. The amended note c. at the definition of “Personal Transaction” reads as follows (presented in context with the root of the definition):

    “A Personal Transaction involves sending money (initiated from the “Personal” tab of the “Send Money” flow) to, and receiving money into your PayPal Account from, friends and family without making a purchase (that is, the payment is not for goods or services). If you are selling goods or services, you may not ask the buyer to send you a Personal Transaction payment for the purchase. If you do so, PayPal may remove your ability to accept any or all payments for Personal Transactions. please note that :

    c. when a fee applies to a Personal Transaction, the sender by default pays the fee, but certain functionality may require the recipient to pay the fee instead (for instance where that functionality allows the sender to decide who pays the fee). In some cases, the sender will not be able to decide and the sender or the recipient will be required to pay the fee. If you send a Personal Transaction payment from a third party (non-PayPal) website or application then PayPal may allow the third party to determine if the sender or recipient of a Personal Transaction payment will pay the Personal Transaction fee. This will be disclosed to you by the third party .”

  13. Categories of countries for the calculation of processing fees for cross border payments

    A key determinant of the relevant processing fee for cross border payments is the region in which the sender’s PayPal account is registered. The Cross Border Fee regions (and their constituent countries) are as follows: We are adding and clarifying the status of certain countries in certain cross border fee regions. Belarus, Georgia and Kosovo have been added to the Europe II region, the status of Macedonia and Moldova as members of the Europe II region has been clarified and the status of Monaco and Montenegro as members of the Europe I region has been clarified. The cross border fee regions (and their constituent countries) are as follows and are updated in the fee statements for cross border Personal Transactions and Commercial Transactions in Schedule 1 –Table of Fees:

    1. Northern Europe: Denmark, Faroe Islands, Finland (including Aland Islands), Greenland, Iceland, Norway, Sweden.
    2. Europe I: Austria, Belgium, Cyprus, Estonia, France (including French Guiana, Guadeloupe, Martinique, Reunion and Mayotte), Germany, Gibraltar, Greece, Ireland, Italy, Luxembourg, Malta, Monaco, Montenegro, Netherlands, Portugal, San Marino, Slovakia, Slovenia, Spain, United Kingdom (including Channel Islands and Isle of Man), Vatican City State.
    3. Europe II: Albania, Andorra, Belarus, Bosnia and Herzegovina, Bulgaria, Croatia, Czech Republic, Georgia, Hungary, Kosovo, Latvia, Liechtenstein, Lithuania, Macedonia, Moldova, Poland, Romania, Russia, Serbia, Switzerland, Turkey, Ukraine.
  14. Commercial Transaction Refund Fee

    We are adding a note on partial refunds in the section about the Commercial Transaction Refund Fee in Schedule 1 –Table of Fees, which reads as follows:

    Commercial Transaction Refund Fee

    Full refunds

    If you fully refund a Commercial Transaction payment, we will retain the Fixed Fee portion of the Commercial Transaction Fee.

    Your buyer’s Account will be credited with the full Commercial Transaction payment amount.

    We will debit from your Account the amount initially credited to your Account in connection with the Commercial Transaction payment and the Fixed Fee portion of the Commercial Transaction Fee.

    Partial Refunds

    If you issue a partial refund of a Commercial Transaction payment, we will retain a pro-rated share of the Fixed Fee portion of the Commercial Transaction fee.

    Your buyer’s account will be credited with the amount you specify to be refunded to your buyer.

    We will debit from your account the pro-rated share of the amount initially credited to your account in connection with the Commercial Transaction payment and the pro-rated share of the fixed fee portion of the Commercial Transaction fee.”

    ,,,

  15. Other changes

    Sections of the PayPal User Agreement have been amended to clarify existing wording and correct minor typographical errors.

 

Amendment to the PayPal Privacy Policy

Effective Date: May 14, 2014

 

Amendment to the PayPal Privacy Policy

  1. Information We Collect

    We are amending section 3 to outline details of further information that we may request from you when you use certain functionalities provided by us and to clarify the types of information about you and your business that we may collect relating to a transaction.

    The amended parts of section 3 now read as follows:

    “3. Information We Collect

    Required Information

    (…)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. If we allow you to link your membership of an eligible loyalty scheme to your Account, we may require you to provide to us your loyalty scheme membership ID.“

  2. Our Use and Disclosure of Information

    We are adding a new part to section 4, labelled “Content Posted by You for Publication”(beneath the part labelled “Internal Uses”) . This paragraph outlines the licence and rights that you give to us and to all subsidiaries of eBay Inc. to use content that you post for publication using the PayPal Services. The new paragraph reads as follows:

    “Content Posted by You for Publication

    When providing us with content or posting content [(in each case for publication, whether on- or off-line)] using the PayPal Services, you grant eBay Inc, and its subsidiaries and subsidiary undertakings (which includes, without limitation, PayPal) (the “eBay Group”) a non-exclusive, worldwide, perpetual, irrevocable, royalty-free, sublicensable (through multiple tiers) right to exercise any and all copyright, publicity, trademarks, database rights and intellectual property rights you have in the content, in any media known now or in the future. Further, to the fullest extent permitted under applicable law, you waive your moral rights and promise not to assert such rights against the eBay Group, its sublicenses or assignees. You represent and warrant that none of the following infringe any intellectual property right: your provision of content to us, your posting of content using the PayPal Services, and the eBay Group’s use of such content (including of works derived from it) in connection with the PayPal Services.”

    The part of section 4 labelled “Disclosure to Other PayPal Customers” has been amended to clarify the circumstances in which we may share certain elements of your information. The amended segment of this part of section 4 now reads as follows (presented in context with the clause heading):

    “Disclosure to Other PayPal Customers

    If you use PayPal as means of logging into external websites or mobile apps, we may share your login status with any third party offering this Service as a login method, as well as the personal and other Account information that you consent to being shared so that the third party can recognise you. PayPal will not give such third party access to your PayPal Account and will only make payments from your Account to that third party with your specific authorisation. You can access, view and control the settings for any such data sharing with merchants when logged into your PayPal account.

    If you link your membership of an eligible loyalty scheme to your Account in our mobile app, we may share your loyalty scheme membership ID with any merchant participating in the relevant loyalty scheme when you pay that merchant using PayPal. If you remove your loyalty scheme membership ID from your Account, we will stop sharing this information.”

  3. Our Use and Disclosure of Information - Disclosure to Third Parties other than PayPal Customers

    Paragraph d. of the part of section 4 labelled “Disclosure to Third Parties other than PayPal Customers” is amended to explain that where you have consented to disclosure of your data to a third party listed in section 4,this will also include the third party’s assigns and successors (i.e. another party that steps into the place of the third party to perform its services to PayPal) The amended paragraph d. reads as follows:

    “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:

    (…)

    d. 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 (which may include their assigns and successors) 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).”

    Just like most banks or financial/payment service providers, PayPal works with third-party service providers. We need to disclose user data to them from time to time so that the services our users have requested can be performed. These service providers provide important functions to us that allow us to be an easier, faster, and safer way to make payments.

    In general, the Luxembourg laws to which PayPal’s handling of user data is subject (data protection and bank secrecy) require a higher degree of transparency than most other EU laws. This is why, unlike the vast majority of providers of internet-based services or financial services in the EU, PayPal lists in its Privacy Policy every third party service provider to whom it discloses user data, together with the purpose of disclosure and type of information disclosed.

    Paragraph d (of the part of section 4 labelled “Disclosure to Third Parties other than PayPal Customers” has been amended to allow PayPal to disclose certain PayPal customer information to additional third parties or for additional purposes for the purposes set out in the table below, or change the scope of purposes and data shared as set out in the table below.

    Category

    Party Name and Jurisdiction (in brackets)

    Purpose

    Data Disclosed

    Customer Service Outsourcing

    Attensity Europe GmbH

    To provide customer services arising from customer contacts to PayPal on social media channels.

    Information provided by the customer via social media channels which may include name, address, phone number, email addresses, social media user names, 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.

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

    To provide customer services regarding payments globally.

    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

    LexisNexis, LexisNexis Risk Solutions UK Limited (UK)

    To assist with customer authentication

    Name, address and date of birth

    Zoot Deutschland GmbH (Germany), Zoot Enterprises Limited (UK)

    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.

    MaxMind, Inc. (USA)

    To detect fraud.

    Please note that data disclosed to this service provider may be:
    • retained by it for audit and fraud prevention purposes;
    • used by it for the purpose of optimising its fraud detection services provided to PayPal and other third parties; and
    • transferred outside of the EU and on a global basis.

    All account information and IP address, credit card information.

    Future Route Ltd (UK)

    To carry out accounting data analysis of our commercial users for real time credit-risk evaluation.

    Name, address, email address and date of birth.

    Financial Products

    Total System Services, Inc. (USA)

    To process merchant initiated and customer authorised payments (including customer direct debit information) to provide account/card processing services, to store transaction, payment and other customer data related to those transactions. To provide call centre services, card printing, and statement printing services.

    Name, address, email address, date of birth (where required), all account information and documents supplied by customers, to include information required to prove identity and address.

    Marketing and Public Relations

    Grayling Communications Limited (UK), Rock Communications (Italy), Fleisher (Israel), Clue PR (Poland).

    To answer media enquiries regarding customer queries.

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

    Oracle America Inc. (USA)

    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.

    Foule Access 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.

    Appnexus, Inc. (US), BlueKai, Inc. (US), Conversant GMBH (Germany), Google Ireland, Ltd.(Ireland),DoubleClick Europe Ltd (UK).

    To execute retargeting campaigns in order to deliver personalised advertising.

    Anonymous ID generated by cookies, pixel tags or similar technologies embedded in webpages

    Criteo SA (France)

    To execute retargeting campaigns in order to deliver personalised advertising.

    Anonymous ID generated by cookies, pixel tags or similar technologies embedded in webpages and emails delivered to users.

    Linkedin Ireland Limited (Ireland)

    To execute retargeting campaigns in order to deliver personalised advertising.

    Encrypted e-mail address associated with PayPal users (without indicating account relationship).

    Conversant 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.

    StrikeAd UK Ltd. (UK), Ad-x Limited (UK)

    To execute and measure retargeting campaigns in order to segment users for PayPal Here marketing campaigns.

    Anonymous cookie ID and device ID to segment user groups for marketing purposes.

    Fiksu, Inc. (US)

    To execute and measure retargeting campaigns in order to segment users for marketing campaigns involving PayPal mobile applications.

    Device ID used for Apple’s iOS operating system when a user installs an application, signs up for the PayPal Services, logs in, checks in, or sets a profile picture.

    Nanigans, Inc. (US)

    To execute retargeting campaigns in order to deliver personalised advertising.

    Advertising ID associated with Apple iOS devices when a user installs an application, relaunches an application, signs up for the PayPal Services, logs in, checks in, checks their balance, saves an offer, successfully completes a transaction, sets a profile picture, or makes other account changes in or related to the use of the application.

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

    To show relevant advertisements to Facebook and Twitter users (as the case may be).

    Encrypted e-mail address associated with PayPal users (without indicating account relationship).

    Purepromoter Ltd t/a Pure360

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

    Mobile Number, 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.

    Operational services

    Kanzlei Dr. Seegers, Dr. Frankenheim & Partner Lawyers (Germany, Austria, Switzerland), Akinika Debt Recovery Limited (UK), Capita Plc (UK), Compagnie Francaise du Recouvrement (France), 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), , Infoscore Iberia (Spain), , SAS (France), Transcom WorldWide S.p.A. (Italy), Transcom Worldwide SAS (Tunisia), Intrum Justitia 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, name of funding source provider and copies of all correspondence in each case relating to amounts you owe (or another person owes) to us.

    KSP Kanzlei Dr. Seegers (Germany), BFS Risk & Collection GmbH (Germany); HFG Hanseatische Inkasso- und Factoring-Gesellschaft (Germany), BFS Risk and Collection GmbH (Germany), Team 4 Collect (Spain), Arvato Polska (Poland), BCW Collections Ireland Ltd (Ireland), S.C. Fire Credit S.R.L. (Romania), Gothia Financial Group AB (Sweden), Gothia AS (Sweden), Gothia A/S (Denmark), Gothia Oy (Finland), Credit Solutions Ltd (United Kingdom).

    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 copies of all correspondence (including without limitation, all correspondence relevant for reporting to credit reference agencies) in each case relating to amounts you owe (or another person owes) to us.

    Begbies Traynor Group plc (UK), Moore Stephens LLP (UK), Moore Stephens Ltd (UK), Moore Stephens International Ltd (UK), Moorhead James LLP (UK), Comas Srl (Italy), RBS RoeverBroennerSusat GmbH & Co. KG (Germany), LLC Elitaudit (Russia), National Recovery Service (Russia).

    To investigate (including, without limitation, to carry out asset and/or site inspections and/or business evaluations) and/or collect (and/or assist with the collection of) debt from potentially and actually 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, name of funding source provider and copies of all correspondence, in each case relating to amounts you owe (or another person owes) to us.

    Hanseatische Inkasso-Treuhand GmbH (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

    Zoot Deutschland GmbH (Germany), Zoot Enterprises Limited (UK)

    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

    Interxion Datacenters B.V.

    To provide data centre operations support for the Bill Safe credit product.

    All relevant account information and transaction information (as appropriate).

  4. Other changes

    Sections of the PayPal Privacy Policy have been amended to clarify existing wording and correct typographical errors.