Privacy-Policy

EU TrustPay is a trade name of CAIRNGORMS HOLDINGS LIMITED Cyprus(the Company) is committed to protect the privacy of individuals who visit the website and who make use of the Company’s web portal .

Data Controller

The data controller of this website is CAIRNGORMS HOLDINGS LIMITED (registration number: HE 423072) whose office is situated at Prodromou 75 Oneworld House Nicosia CY, 2063 Cyprus

BThis Privacy Policy sets out the basis on which any customer personal information held by the company will be processed. Whenever you provide the company with information or data such as completion of forms, call our Customer Support Desk or submit details via the company’s web portal, the company will use your personal information in the manner described in this Privacy Policy.

Information collected and held about you

We may collect and process the following data about you:

  • Your personal details including your full name, email address, residential address, telephone number, date of birth, proof of identity and tax identification number;
  • Details of any transactions you carry out through our web portal using your EUTrustPay Account and of the fulfillment of your requests;
  • Your personal Bank Account details which you use to load your EUTrustPay Account;
  • Credit, debit or other card used by your good self to conduct transactions;
  • Correspondence that we receive from you;
  • Phone calls made to you by us, or phone calls that you make to us;
  • Information collected through Cookies;
  • Your IP address, log-in times, operating system and browser type;
  • Details of your visits to our web portal including amongst others, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access whilst visiting our Website

Information Collected and held from/by service providers

Whenever your personal data is processed and stored by payment facilitator partners and credit/debit card processors involved in the execution of payment transactions or the provision of our products and services, we make sure that your data is encrypted and stored in compliance with PCI DSS regulations. If we transfer your personal data to another service provider located in another country, we will make sure that they agree to apply the same levels of protection as we are required to apply to your information and to use your information strictly in accordance with our instructions. We require these third parties to not use your personal information for any other purpose.

When sending money to another EUTrustPay Account holder, sending money and inviting that recipient to open an account with us, or when you request payment from your client(s), at a minimum, we pass on your email address to the recipient.

Storing your personal data

Where is it stored?

The information that we collect from you will be stored in destinations within the European Economic Area (EEA). This information may be transferred to destinations within or outside the EEA. The reasons that data could be transferred and stored outside the EEA include:

  • if this is necessary for providing you with the services you request. For example if you transfer funds to a merchant that is not located in the EEA, it will be necessary to send your details to that merchant,
  • where our anti-fraud agencies, credit reference agencies and other service providers are based outside the EEA and require access to your data to perform their obligations to us and provide services to you;
  • if you have been referred to us by a third party and the latter is entitled to a commission payment. We have taken and will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy no matter where it is located.

Security

We are committed to ensuring that your personal details are secure. Thus, so as to prevent unauthorised access or disclosure of information we have physical, electronic and managerial procedures in place to keep your information safe.

It is however of utmost importance that you follow certain security practices to ensure a higher level of security, such as:

You should be the only person who accesses your EUTrustPay Account and therefore your log in details should not be shared with anyone (not even family members). On the other hand, if you have a suspicion that your login details have been compromised, you should change them immediately from your profile section from the EUTrustPay portal. In addition, you should contact our Customer Support Desk on [email protected] and tell us why you think your login details have been compromised.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

Retention

The company shall retain personal data, including documentation and information, for use in an investigation into, or an analysis of, the possibility of Money Laundering/Financing of Terrorism (ML/FT), for a period of six (6) years from when the business relationship is terminated (closure of your EUTrustPay account). These records can be requested by the Financial Intelligence Analysis Unit (FIAU) or by other competent authorities as required.

Disclosure of your information to other third parties

If we suspect that we have been given false or inaccurate information, we may record our suspicion together with any other relevant information. Personal data may also be transferred confidentially to other organisations involved in issuing or operating your Card so that we can administer your Card correctly. Your information may also be disclosed to other third parties, including, Merchants, Fraud/Anti-Money Laundering Agencies, other competent authorities and 3rd parties to whom you have consented us to provide information about you such as but not limited to your external auditors.

Communicating with you

Personal data will not be processed by the Company for the purposes concerning direct marketing, unless you expressly gives us your consent to process your data for such purposes.

Please ignore any email purporting to have been sent by EUTrustPay requesting confirmation on login and/or other personal details. Such emails are fraudulent in nature. It is important not to click on any links provided in the email. If you do so, you might end up providing information to a fraudster!

Telephone recordings

We may monitor and/or record telephone calls we have with you or any Additional Cardholder to help us maintain and improve the quality of our Customer Service or as required by applicable law.

Links to other Web Sites

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

Cookies

Cookies are small pieces of data that the site transfers to the user’s computer hard drive when the user visits the website. Our website uses session cookies which are erased when the user closes the Web browser, and Analytics Cookies as identified by Google Analytics. The session cookies are stored in temporary memory and are not retained after the browser is closed. Session cookies do not collect information from the user’s computer. Session cookies are used to retain information pertaining to the site layout and allow a temporary tagging of the site user. They will typically store information in the form of a session identification number, this does not personally identify the user. Analytics cookies allow for identification of the site user’s location as well as where the site has been accessed from, however this is un-personal and is not used to identify any personal information from the site user.

Your rights as data subject

As an individual you may exercise your right to access the data held about you by this company by submitting your request by email on dataprotection@ eutrustpay.com

Although all reasonable efforts will be made to keep your information updated, you are kindly requested to inform us by sending us an email on dataprotection@ eutrustpay.com of any change referring to your personal data. The company shall not be liable for any loss arising out of your failure to keep your personal details up to date.

In any case if you consider that certain information about you is inaccurate, you may request rectification of such data. You also have the right to request the blocking or erasure of data which has been processed unlawfully. Furthermore, after termination of your relationship with Confienza you have the right to request that all personal data and other information about you be deleted from Confienza, subject to Confienza’s obligations as subject person.

Transaction Security Policy

The company ensures that all sensitive payment data exchanged via the internet uses secure end-to-end encryption between the communicating parties throughout the respective communication session, in order to safeguard the confidentiality and integrity of the data, using strong and widely recognized encryption techniques.

Feedback – Contact Us

Any comments or queries regarding this Privacy Policy should be submitted to the company through the ‘Contact Us’ tab.

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