User Agreement - Privacy Statement

Privacy Statement

Effective Date: March 16, 2022

Overview
What Personal Data Do We Collect?
Why Do We Retain Personal Data?
How Do We Process Personal Data?
Do We Share Personal Data?
How Do We Work with Other Services and Platforms?
How Do We Transfer Data Internationally?
How Do We Use Cookies and Tracking Technologies?
What Privacy Choices Are Available To You?
What Are Your Rights?
How Do We Protect Your Personal Data?
Can Children Use Our Services?
What Else Should You Know?
Contact Us
Definitions
Additional Information

1. Overview

PayPal has developed this Privacy Statement to explain how we may collect, process, disclose, store, and transfer your Personal Data when you visit our Sites or use our Services.

This Privacy Statement applies to your Personal Data when you visit Sites or use Services, and does not apply to online websites or services that we do not own or control, including websites or services of other PayPal Users.

This Privacy Statement is designed to help you access information about our privacy practices and to help you understand your privacy choices when you use our Services. Please note that our Service offerings may vary by region. This Privacy Statement may be supplemented with additional notices depending on the Sites and Services concerned. Supplementary information can be found in the Statement on Cookies and Tracking Technologies and the Banking Regulations Notice.

We have defined some terms that we use throughout the Privacy Statement. You can find the meaning of a capitalised term in the Definitions section.

By visiting the Sites or using the Services you hereby grant us, Limited Liability Company Non-Banking Credit Institution "PayPal RU", a credit institution established under Russian law, located at Butyrskiy Val St., 10, 125047, Moscow, Russian Federation, as well as our affiliates, and third parties performing identification, simplified identification or verification procedures and services, your consent to process (collecting, recording, systematization, accumulation, storage, verification (renewal, modification), extract, use, transfer (including dissemination, disclosure, provision, access), de-personification, blocking access, deletion or destruction) your Personal Data collected by us, our affiliates or third parties performing identification, simplified identification or verification procedures and services, in accordance with this Privacy Statement. You hereby confirm that you have been notified of the fact and you grant us your express consent that your Personal Data may be transferred to foreign states and third parties as provided in this Privacy Statement.

2. What Personal Data Do We Collect?

We collect and retain Personal Data about you when you visit our Sites or use our Services, including the following:

Registration and use information – When you register to use our Services by creating an Account, we will collect Personal Data as necessary to offer and fulfil the Services you request. Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services.
Transaction and experience information – When you use our Services or access our Sites, for example, to make purchases from merchants, to receive money, to process payments, or to send money to friends and family, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information.
Participant information – When you use our Services or access our Sites, we collect Personal Data you provide us about the other participants associated with the transaction.

Send or request money: When you send or request money through the Services, we collect Personal Data such as name, postal address, telephone number, and financial account information about the participant who is receiving money from you or sending money to you. The extent of Personal Data required about a participant may vary depending on the Services you are using to send or request money.
- Pay or request someone else to pay a bill: If you use our Services to pay a bill for the benefit of someone else, or if you request a User to pay a bill for you, we collect Personal Data from you about the account holder such as name, postal address, telephone number, email address, and account number of the bill that you intend to pay or request to be paid.
Add value to your account: If you use our Services to add value to your Account or any other account you may have, or if you ask a User to add value to any of these accounts, we may collect Personal Data from you about the other party, or from the other party about you to facilitate the request. For example, if you use our Services to reload a mobile phone, or to request value be added to your mobile account, we may collect Personal Data and other information including mobile account number from the other participant.

Personal data that you choose to provide us to obtain additional Services or specific online services – If you request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection, if the use of that Personal Data differs from the uses disclosed in this Privacy Statement.
Personal Data about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.
Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

Non-Account holders

If you use our Services without creating or logging into an account, we’ll still collect personal data, which may include your payment information, device information, and location. When you use our Services without creating or logging into an account, we will use this information to process transactions, prevent fraud and comply with the law. We may connect this information with your account, if you have one or if you create an account at a later date.

3. Why Do We Retain Personal Data?

We retain Personal Data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to delete (destruct) or pseudonymised (depersonalize) Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Statement.

The cookies we use have defined expiration times; unless you visit our Sites or use our Services within that time, the cookies are automatically disabled and retained data is deleted. Please consult our Statement on Cookies and Tracking Technologies for more information.

4. How Do We Process Personal Data?

We may Process your Personal Data for a variety of reasons that are justified under Russian data protection laws.

To operate the Sites and provide the Services, including to:
- initiate a payment, send or request money, add value to an account, or pay a bill;
- authenticate your access to an Account;
- communicate with you about your Account, the Sites, the Services, or PayPal;
- create an account connection between your Account and a third-party account or platform;
- perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes; and
- keep your Account and financial information up to date.
To manage our business needs, such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality. For example, we analyze User behavior and perform research about the way you use our Services.
To manage risk and protect the Sites, the Services and you from fraud by verifying your identity; PayPal’s risk and fraud tools use Personal Data, Device Information, Technical Usage Data and Geolocation Information from our Sites and websites that offer PayPal Services to help detect and prevent fraud and abuse of the Services.
To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.
For our legitimate interests, including to:
- enforce the terms of our Sites and Services;
- manage our everyday business needs, such as monitoring, analysing;
- manage risk, fraud and abuse of PayPal Services;
- anonymise Personal data in order to provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services; and
- provide personalised Services (also called interest-based marketing) offered by PayPal on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Statement to provide a targeted display, feature or offer to you on third-party websites.
- To make it easier for you to find and connect with others. For instance, if you let us access your contacts or when your Account profile is public , we can suggest connections with people you may know and help others connect with you to send you money by letting them find your profile when they search for you by name, username, email, or mobile number on PayPal. We may also associate information that we learn about you through your and your contacts’ use of the Services, and information you and others provide, to suggest people you may know or may want to transact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service.
With your consent, including to:
- To market to you about PayPal products and Services and the products and services of unaffiliated businesses. We may also Process your Personal Data to tailor the marketing content and certain Services or Site experiences to better match your interests on PayPal and other third-party websites.
- To use cookies and other tracking technologies to provide a targeted display, feature, Service or offer to you and/or to work with other third-parties such as merchants, advertising or analytics companies to provide these personalized services (also called interest-based marketing).
- To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the Sites and Services and provide you with location-based Services, such as advertising, search results, and other personalised (also called interest-based marketing) content.
- To respond to your requests, for example to contact you about a question you submitted to our customer service team.

You can withdraw your consent at any time and free of charge. Please refer to the section on “Your Privacy Choices” for more information on how to do that.

5. Do We Share Personal Data?

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Statement. We may share your Personal Data or other information for the following reasons:

With other members of the PayPal corporate family: We may share your Personal Data with members of the PayPal family of entities to, among other things, provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of PayPal products, Services, and communications.

With other companies that provide services to us: We share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support.

With other financial institutions: We share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product. These financial institutions may only use this information to market and offer PayPal-related products, unless you have given consent for other uses. We may also share Personal Data to process transactions, provide you with benefits associated with your eligible cards, and keep your financial information up to date.

With the other parties to transactions when you use the Services, such as other Users, merchants, and their service providers: We may share information about you and your Account with the other parties involved in processing your transactions. This includes other Users you are sending or receiving funds from, and merchants, and their service providers. The information might include:

Personal Data and Account information necessary to facilitate the transaction;
Personal Data to help other participant(s) resolve disputes and detect and prevent fraud; and
Anonymous data and performance analytics to help merchants better understand the uses of our Services and to help merchants enhance Users’ experiences.

With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for PayPal’s business purposes or as permitted or required by law, including:

if we need to do so to comply with a law, legal process or regulations;
to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to PayPal or PayPal’s corporate family;
if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
to protect the vital interests of a person;
with credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes;
to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
to protect our property, Services and legal rights;
to facilitate a purchase or sale of all or part of PayPal’s business;
in connection with shipping and related services for purchases made using a Service;
to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants;
to banking partners as required by card association rules for inclusion on their list of terminated merchants;
to credit reporting and collection agencies;
to companies that we plan to merge with or be acquired by; and
to support our audit, compliance, and corporate governance functions.

With your direction: We also will share your Personal Data and other information with your direction, including if you authorize an account connection with a third-party account or platform.

In addition, PayPal may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent.

6. How Do We Work with Other Services and Platforms?

A significant benefit and innovation of PayPal’s Services is that you can connect your Account with a third-party account or platform. For the purposes of this Privacy Statement, an “account connection” with such a third-party is a connection you authorize or enable between your Account and a non-PayPal account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, PayPal and the third-party will exchange your Personal Data and other information directly. Examples of account connections include:

linking your Account to a social media account or social messaging service;
connecting your Account to a third-party data aggregation or financial services company, if you provide such company with your Account log-in credentials; or
using your Account to make payments to a merchant or allowing a merchant to charge your Account.

If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Account to a social media account, we will receive Personal Data from the social media provider via the account connection. If you connect your Account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases and funds transfers. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Statement.

Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that you authorized to have an account connection that will gain access to your Personal Data as part of the account connection. For example, Personal Data that PayPal shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.

7. How Do We Transfer Data Internationally?

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers.

The parties mentioned above may be established in jurisdictions other than your own and outside Russia. These countries do not always afford an equivalent level of privacy protection. We have taken specific steps, in accordance with Russian data protection law, to protect your Personal Data.

In case you make transactions with parties outside Russia or connect our Service with platforms, such as social media, outside Russia, we are required to transfer your Personal Data with those parties in order to provide the requested Service to you.

8. How Do We Use Cookies and Tracking Technologies?

When you visit our Sites, use our Services, or visit a third-party website for which we provide online services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.

Please review our Statement on Cookies and Tracking Technologies to learn more about how we use Cookies.

9. What Privacy Choices Are Available To You?

You have choices when it comes to the privacy practices and communications described in this Privacy Statement. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services.

Choices Relating to the Personal Data We Collect
- Personal Data. You may decline to provide Personal Data when it is requested by PayPal, but certain Services or all of the Services may be unavailable to you.
- Location and other device-level information. The device you use to access the Sites or Services may collect information about you, including Geolocation Information and User usage data that PayPal may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
Choices Relating to Our Use of Your Personal Data
- Online Tracking and Interest-Based Marketing. We work with partners and third-party service providers to serve you advertising using ad-related cookies and web beacons. You can opt-out of third-party advertising-related cookies and web beacons, in which case our advertising should not be targeted to you. You will continue to see our advertising on third party websites.
  - For more information on third-party advertising-related cookies and interest-based marketing, and to learn how to opt-out of these practices with companies participating in industry self-regulation, please visit Your Online Choices.
- Finding and connecting with others. If available, you may manage your preferences for finding and connecting with others from your account of the Service you use.
Choices Relating to Account Connections

If you authorize an account connection to a third-party account or platform, such as a social media account, you may be able to manage your connection preferences from your Account or the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices you may have.

Choices Relating to Communications and Advertising

Administrative communications: We will send communications to you that we are required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may be able to adjust the media and format through which you receive these notices.

Please review our Statement on Cookies and Tracking Technologies to learn more about how to adjust cookie configurations accordingly.

Choices Relating to Your Registration and Account Information

If you have an Account, you generally may review and edit Personal Data by logging in and updating the information directly or by contacting us. Contact us if you do not have an Account or if you have questions about your Account information or other Personal Data.

Choices Relating to Communication

Notices, Alerts and Updates from Us:
Marketing: We may send you marketing content about our Sites, Services, products, products we jointly offer with financial institutions, as well as the products and services of unaffiliated third parties and members of the PayPal corporate family through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications we send by following the instructions in the communications you receive. If you have an Account with us, you may also adjust your communication preferences in your Account settings. For messages sent via push notifications, you may manage your preferences in your device.
- Informational and Other: We will send communications to you that are required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.

10. What Are Your Rights?

Subject to limitations set out in Russian data protection laws, you have certain rights in respect of your Personal Data. In particular, you have a right of access, rectification, restriction, opposition, erasure and data portability. Please contact us if you wish to exercise these rights.

If you have an Account with any of our Services, you generally can review and edit Personal Data in the Account by logging in and updating the information directly. PayPal may use automated decision-making for decisions concerning credit with your consent or where necessary for the entry into or performance of a contract or authorised by Union or Member state law.

Please contact us if you require more information on automated-decision making.

11. How Do We Protect Your Personal Data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorization controls. While we are dedicated to securing our systems and services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized.

12. Can Children Use Our Services?

The Sites and Services are not directed to children under the age of 13. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

13. What Else Should You Know?

Changes to this Privacy Statement.

We may revise this Privacy Statement from time to time to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Statement will be effective as of the published effective date.

If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Users of the change using email or other means.

14. Contact Us

You may contact us if you have general questions or concerns about this Privacy Statement and supplemental notices or the way in which we handle your Personal Data.

We want to make sure your questions go to the right place:

Click here to contact us about your PayPal account
Click here to contact us about your Xoom account

If you are not satisfied by the way in which we address your concerns, you have the right to lodge a complaint with the Supervisory Authority for data protection in your country.

Our Data Protection Officer can be contacted Online or PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg.

15. Definitions

Account means a PayPal or Xoom member account.
Device Information means data that can be automatically collected from any device used to access the Site or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device IP address; information about your device’s web browser and internet connection you use to access the Site or Services; Geolocation Information; information about apps downloaded to your device; and biometric data.
Geolocation Information means information that identifies, with reasonable specificity, your location by using, for instance, longitude and latitude coordinates obtained through GPS or Wi-Fi or cell site triangulation.
PayPal means Limited Liability Company Non-Banking Credit Institution “PayPal RU” (main state registration number: 1137711000041, address: Butyrskiy Val st., 10, Moscow 125047, Russia) and subsidiaries or affiliates. In this Privacy Statement, PayPal is sometimes referred to as “we,” “us,” or “our,” depending on the context.
Personal Data means information that can be associated with an identified or directly or indirectly identifiable natural person. “Personal Data” can include, but is not limited to, name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport number, ).
Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.
Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by PayPal or Xoom.
Sites means the websites, mobile apps, official social media platforms, or other online properties through which PayPal offers the Services and which has posted or linked to this Privacy Statement.
Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Sites or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies.
User means an individual who uses the Services or accesses the Sites.

16. Additional Information

The information provided in this section may be specific to customers depending on your region or is provided to PayPal from third parties whom you may interact with when using the Services. You can contact us if you have any questions about the details in this section.

Google ReCaptcha

PayPal uses ReCaptcha on the Sites and Services. Your use of ReCaptcha is subject to the Google Privacy Policy and Terms of Use.

ReCaptcha is only used to fight spam and abuse.