Privacy Policy
STP Groep B.V. PRIVACY STATEMENT
INTRODUCTION
Please read this statement carefully to understand our policies and practices regarding your personal information and how we will treat it. Our Contact details are provided at the end of the statement for feedback.
This statement applies to the companies that are part of STP Groep, which may use different trading names in different territories, and the list of these companies that collect or process personal information according to this statement can be found at the end of this document. The reference to STP Groep (including “we”, “us” or “our”) includes those companies and all relevant group affiliates. This statement will not override any rights provided to you under the local privacy and data protection laws that apply in your jurisdiction.
References to “you” in this statement are to the individual who is accessing or applying to use the Services (as defined below) either on your own account or on behalf of a business. This includes, in relation to a customer or prospective customer of STP Groep, any sole trader and any principals, including the managing and financial directors, any other directors and officers, shareholders, partners and beneficial owners of a customer, as well as any member of staff accessing or using the Services on behalf of a customer.
STP Groep is committed to protecting your privacy and will take all appropriate steps to ensure that your personal information is treated securely and will be collected, used, stored, and disclosed in accordance with this statement. This statement (together with our terms of use applying to any specific services you may purchase or use) applies:
to the website/portal features and services provided to you when you visit our websites, portals, or our payment panels our clients may use on their websites.
when you apply to use and/or use STP Groep’s products and services (including any loyalty or reward schemes, whether points-based or otherwise (“Loyalty”), as well as when you request changes to the services you are using.
to your use of software including terminals, mobile and desktop applications provided by STP Groep; and
to email, other electronic messages including SMS, telephone, web chat, website/portal and other communications between you and STP Groep.
Together these are all referred to in this statement as “Services”.
INFORMATION WE MAY COLLECT FROM YOU
We collect and process personal and non-personal information relating to you.
Personal information is information that can be used to uniquely identify a single person, either directly or indirectly.
STP Groep also collects non-personal information or may anonymize personal information to make it non-personal. Non-personal information is information that does not enable a specific individual to be identified, either directly or indirectly. STP Groep may collect, create, store, use, and disclose such non-personal information for any reasonable business purpose. For example, STP Groep may use aggregated transactional information for commercial purposes, such as trend analysis and the use of data analytics to obtain learnings and insight around payment transaction patterns and usage.
To the extent that Internet Protocol (IP) addresses (or similar identifiers) are clearly defined to be personal information under any local law, and where such local law is applicable to Services, we will manage such identifiers as personal information.
Please note that STP Groep provides services to both individual consumers and businesses and this privacy statement applies to both and should be read and interpreted accordingly.
SPECIAL CATEGORY DATA
We may collect information about you that is of a sensitive nature, such as so-called special category data or sensitive data. These types of information can relate to an individual’s:
Racial or ethnic origin
Political opinions
Religious or philosophical beliefs
Trade union membership
Genetic data
Biometric data
Health data
Data that relates to an individual’s sex life or sexual orientation
Data about criminal offenses or alleged crimes
Data about an individual’s location in real-time
Local laws may prohibit or restrict the use of such data and require specific obligations to be met. Within Europe, GDPR will generally require a second lawful basis for such processing, such as, (a) your explicit consent, (b) for the purposes of the establishment, exercise, or defense of legal claims, (c) for reasons of substantial public interest, or (d) where processing is necessary for your vital interests or of another natural person.
INFORMATION COLLECTION
We collect the following information through the following means:
Information you give us: we receive and store any personal information (including financial information) you provide to us including when you (or your business) enquire for or make an application for the Services; register to use and/or use any Services; upload and/or store information with us using the Services; and when you communicate with us through email, SMS, a website or portal, or the telephone or other electronic means, e.g. in the context of contacting us about your account or transactions. Such information may reference or relate to you or your customers and includes:
Name including first name and family name, date of birth, age, email address, billing address, username, password and/or photograph, biometric information, address, occupation, nationality and country of residence, a copy of your identification, such as your driver’s license or passport, your social security number and/or other government identification or registration data.
Card primary account number, card expiry date, CVC/CVV details (card security code), account numbers, account balances and the length of time you have maintained those accounts, bank and/or issuer details.
Information relating to any items purchased, including the location of the purchase, the value, the time and any feedback that is given in relation to such purchase, including travel- related personal information when you or your customer are transacting for airline tickets or other travel related services.
Information about your use of the Services, such as information about how frequently you transact with us, your transactions and average transaction volume, account balances, the people and merchants to whom you send money and from whom you receive money, and, where you provide consent, information from your contact list.
Points or rewards earned or redeemed in any Loyalty program that the Company wishes to implement or not implement.
Photos and videos taken during any STP Groep events you have registered for, for distribution to event participants and in our promotional materials for future events; and
Any other information that you or your customer provide or is generated in the context of using the Services.
Information we collect about you automatically:
STP Groep receives and stores certain information automatically whenever you interact with STP Groep, whether you open an account or undertake a transaction with us; for example, by way of “cookies” or similar technology. We also obtain certain information when your web browser accesses Services or advertisements and other content provided by or on behalf of STP Groep on other websites, or when clicking on emails. Collecting this information enables us to better understand the visitors and customers who use and interact with STP Groep, where they come from, and how they use our services. We use this information for our analytics purposes and to improve the quality and relevance of our services for our visitors and customers.
This information includes:
Technical information, including the Internet protocol (IP) address used to connect your computer or device to the Internet, your login information, browser type and version, equipment type, time zone setting, browser plug-in types and versions, operating system platform, frequency and length of visits, and what links you click on. For fraud and security purposes, the use of proxy IP addresses is generally forbidden when linking to STP Groep systems.
Information about your visit or whether you opened an email, including your geolocation (this may include software and services we use to verify your address for regulatory or risk purposes by determining whether an address you indicate matches the IP address of your log-in device), the full Uniform Resource Locators (URL) clickstream to, through and from our site(including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the site page and any phone number used to call our customer service number.
Information collected through our applications:
If you download or use mobile or desktop applications provided by STP Groep, we may receive information about your location and your device or the service you are using (including where a payment transaction takes place). Some devices allow applications to access real-time location-based information (for example GPS). Our mobile and desktop apps may collect such information from your mobile device or your computer at any time while you download or use our apps, if your device has real-time location data access enabled. Where required, we will always seek to notify you if it is our intent to collect real-time location information and, also where required by law, obtain your consent. We may use such information for regulatory purposes, our own due diligence checks, fraud, and risk management, to better understand transaction patterns and to optimize your experience.
Email and Other Communications: we may receive information about you and your use of Services when we communicate with each other, including when you open messages from us and from the use of electronic identifiers (sometimes known as “device finger-prints”), for example, Internet Protocol addresses or telephone numbers.
Information from Other Sources:
We may receive information about you from other sources and add it to our account information, including when you apply to use the Services. For example, we may cooperate or work closely with, and receive information from third parties such as business partners, banks and other financial institutions, merchants, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, third-party data brokers, government lists and databases social media sites (including postings made by or about you or us), and fraud prevention agencies. We may also review public comments and opinions made on social networking sites (e.g., Facebook and Twitter) to better understand our customers and our provision and development of Services.
Information about other people:
If you give us information about other people, you must have informed them in advance (for example, by giving them this privacy statement) and you must ensure you have the right to do so.
WHAT WE USE YOUR DATA FOR
We may use and share the personal information we collect for the following purposes:
To provide our Services to you and your business, including fulfilling STP Groep’s obligations to you or to financial or other institutions in connection with the Services we provide to you (and/or your business). In this context we record and track details of transactions you (and/or your customers) carry out in relation to the Services; analyze and report on your (and/or your customers’) use of any Loyalty service; facilitate the collection or redemption of any points or other rewards currency in respect of any Loyalty program; notify you about important changes or developments to our website or our goods and services.
To improve and develop our business, including without limitation to optimize our websites/portals, products, and services. This may include using the information you insert into forms but do not submit to us, for example by using that information to optimize our website(s) and contacting you for customer services or marketing purposes in relation to that form. We can also use your personal information to develop and test new products and services including in our secure and controlled test environment, or occasionally in those of our suppliers.
To manage and enforce our rights, terms of use or any other contracts with you (and/or your business), including to manage any circumstances where transactions, rewards or points are disputed; manage, investigate, and resolve complaints; or recover debtor in relation to your insolvency.
To prevent and/or detect fraud, financial crime, manage risk and to better protect ourselves, our customers, and the integrity of the financial system, it may be necessary to process and disclose sensitive or higher risk personal information (special category personal data) including biometric data to third parties who help us in managing such risks, including identity verification. This may include software and services we use to verify your identity/age by determining whether a selfie you take matches the photo in your ID.
During the identification process we may use a facial recognition process to compare your selfie with your uploaded ID document. During this process biometric data is generated by creating a digital map of your face to better compare your ID photo and your selfie picture. This helps to reduce fraud and is therefore in the substantial public interest. Any biometric information generated is immediately deleted following a match. STP Groep itself does not generally store or retain biometric data because such information is generally generated using secure third-party anti-fraud systems.
If your biometric information is stored, retained, or used directly by STP Groep in any way, you will be notified at the point of collection. If you want to know more about our policies and processes in respect of your biometric data, or indeed our use of any other sensitive, higher risk or special category personal data, you can reach us at the details provided in the “Contact Us” section.
To prevent, detect and prosecute fraud and other crimes and abuses of the financial system, or to assist others in doing so, including non-compliance with any terms of business and which may involve the sharing of any relevant or necessary information we have collected or inferred with third parties for such purposes. STP Groep participates in anti-fraud initiatives, which involve assessing you (and/or your customers) and monitoring your transactions and/or locations, to detect patterns requiring investigations or otherwise profile and assess the likelihood of fraud occurring or non-compliance with our or other’s terms of business. We can do so by utilizing products and services from third parties. Besides, if you give us false or inaccurate information about you, or we identify or suspect fraud or a crime, we may pass your information to fraud prevention agencies and organizations and to law enforcement agencies and similar bodies, and we may decide to take legal action against you.
Where permitted by law, we may use information related to financial well-being and other credit or risk factors to make decisions on the pricing of our Services.
To contact you about your account, to alert you to potential problems, and to respond to your questions to us.
To manage risks, such as credit and foreign exchange risks, as well as to prevent or mitigate information security risk.
To send marketing messages, to provide you with the information on products and services you have requested, or we think may be of interest to you; To obtain your views on our goods, services and our website/s; in respect of marketing, market research and similar activities, we may use your personal information for such purposes whether or not you are accepted as a customer or continue to receive Services. If you no longer wish to receive marketing or promotional information from STP Groep, you can always stop it. You can find more information in the section “Your Data Protection Rights”.
To comply with local and international laws such as GDPR.
To comply with requests from law enforcement and regulatory authorities on public interest grounds or from commercial organizations with whom you have or have had dealings, to establish, exercise or defend legal claims, or to protect your vital interests or those of other persons; for example, to help those authorities or other organizations in the fight against crime and terrorism; and
To comply with card scheme rules or any terms of business.
If you provide information to be published or displayed on public areas of the website/portal or transmitted to other users of the website/portal or third parties, you understand that such information can be used by any third parties accessing the information for any purposes. This information is posted by you at your own risk, and you must comply with the terms of use of such site.
HOW DO WE WORK WITH OTHER SERVICES AND PLATFORMS
Where available, you may be able to 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-STP Groep account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, STP Groep and the third-party will exchange your Personal Data and other information directly. Examples of account connections include:
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 create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. If you connect your Account to a third-party, 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 statement 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 STP Groep 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 public, depending on the accounts or platform’s privacy practices.
MONITORING
We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, quality assurance or training purposes. When visiting our offices, CCTV, access control systems and/or other monitoring systems may be in operation for security reasons and for health and safety and office management purposes.
WHERE WE STORE YOUR PERSONAL DATA
We, our service providers, and other parties with whom we may share your personal information (as described above) may process your personal information in territories that are outside the European Economic Area (“EEA”) or otherwise outside of the territory in which you reside. It may also be processed by staff (ours or that of our suppliers) operating outside the EEA or the territory in which the personal information was collected. Such staff may be engaged in, among other things, the fulfillment of orders, the processing of payment details and support services in provision of the Services. These countries may have data protection standards that are different to (and, in some cases, lower than) those of the territory in which you reside.
In these circumstances, we will take appropriate steps to protect your personal information in accordance with this privacy statement and applicable data protection laws; including using any appropriate safeguards required by law to ensure that any international data transfers are lawful. STP Groep generally uses “Model Clauses”( Standard Contractual Clauses) as approved by the European Commission when contracting with third-party data recipients outside the EEA who are receiving data from within the EEA for the purpose of processing personal information transferred outside the EEA.
HOW WE KEEP YOUR PERSONAL DATA SECURE
We have implemented technical, physical, and organizational/administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures include:
Written information security program.
Continuous vulnerability assessment and monitoring.
Having information security risk management policies and procedures in place.
Having an established incident response plan.
Access controls on information systems, designed to authenticate users and permit access only to authorized individuals.
Restricting access to physical locations containing personal information only to authorized individuals.
Securing all personal information, both in transit and at rest.
Multifactor authentication for all staff accessing personal information.
Maintaining audit trails relating to internal and external access to and modifications of personal information.
Adopted secure development practices for in-house developed applications.
Performing information security due diligence on third-party service providers.
Performing security awareness training on a regular basis.
The safety and security of your information is also dependent upon you. If we have given you (or if you have chosen) a password or access code for access to certain parts of our website/portal or mobile applications and similar, you are responsible for keeping this password and/or access code confidential. You must not share your password and/or access code with anyone. You must ensure that there is no unauthorized use of your password and access code. STP Groep will act upon instructions and information received from any person that enters your user id and password and you understand that you are fully responsible for all use and any actions that may take place during the use of your account, unless otherwise mandated by law. You must promptly notify STP Groep of any information you have provided to us which has changed.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site, unless you are communicating with us through a secure channel that we have provided. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We will retain your personal information for as long as needed or permitted depending on the context and purpose for which it was collected, the type of information and in compliance with applicable local laws or regulations.
This means that when using our Services, we will retain your personal information as necessary for the provision of the services and for any linked legitimate business purpose. This includes the use and retention of your personal information when you commence an application for our services, irrespective of whether you complete such application or are accepted as a customer. For example, account data is generally retained for 5 to 20 years after the closure of the account, to align with statute of limitation periods in the event of complaints or legal disputes. We may
also be legally required to retain information, for example under anti money laundering or bankruptcy laws or where required by law enforcement or similar government agencies.
We will retain personal information as evidence of our dealings with you regardless of whether there were any financial transactions, for audit and compliance practices, to manage any queries or disputes, including to defend or initiate any legal claims. We can also continue marketing and sending you direct marketing, subject to local laws and where you have not objected to such marketing.
We may also use data minimization techniques to better protect your information, known as pseudonymization. Once your information is no longer needed, we may anonymize or aggregate it with other information to make it unidentifiable, as an alternative to deletion.
YOUR DATA PROTECTION RIGHTS
Depending on your jurisdiction or country of residence, you may have one or more of the following rights:
Right to be informed: including by being provided with this statement
Right to access: request a copy of the information we hold about you
Right to erasure: request deletion of your information
Right to restriction: request we restrict the processing of your information
Right to rectification: request we rectify certain information we hold about you
Right to data portability: request that we provide you or another organization with an electronic copy of the information you provided to us
Right to object: request we stop processing your personal information
Right to opt-out of marketing: remove your information from our marketing database
Rights related to automated decision-making including profiling: see section "Automated Decision Making" below.
These rights may apply under several different regulations, for example, the General Data Protection Regulation, generally applicable to EEA residents.
Furthermore, such rights may be qualified or restricted. For example, we may not be obligated to grant your request as we may be required by law to continue its processing, or to manage a complaint. Similarly, we are unable to delete your information if you want to continue using our Services, or where such information is necessary to record our contractual dealings; it is required by law (for example, the retention of anti-fraud or “know your customer” identify and verification requirements); or for the purpose of defending or asserting legal rights and legal actions.
When you cease your relationship with us and stop using our services, we are permitted by law to retain your information for a period to evidence our dealings with you, as explained earlier. This will be in accordance with our internal retention policies and procedures. For more information on retention of data, please refer to the relevant section within this Statement.
To the extent that GDPR applies, when you give us consent to use your personal information, you can withdraw it any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You always have the right to complain to a data protection authority if you are dissatisfied about our collection and use of your personal information. For more information, please contact your local data protection authority. Also, you may be able to commence a court action to claim compensation for damage or distress caused by our failure to comply with data protection legislation.
If you want to know more about your rights, or you want to exercise them, please visit our dedicated rights page on our STP Groep website. Here you can submit a rights request directly to the relevant team. Alternatively, you can reach us at the details provided in the Contact Us section.
AUTOMATED DECISION MAKING
In some instances, our use of your personal information may result in automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you.
Automated decisions mean that a decision concerning you is made automatically based on a computer determination (using software algorithms), without our human review. For example, we use automated decisions when you apply for certain Services or to carry out anti-fraud checks, as explained in the section “What We Use Your Personal Information For”. We have implemented measures to safeguard the rights and interests of individuals whose personal information is subject to automated decision-making. In addition, if you are using the Services in the EEA, when we make an automated decision about you, you have the right to contest the decision, to express your point of view, and to require a human review of the decision. To exercise this right, please complete our dedicated rights form or contact us via the details provided in the ‘Contact Us’ section. Privacy laws continue to develop and if you think or are unsure as to whether such right may apply to you, please also contact us, so we can assess and advise.
LEGAL BASIS FOR PROCESSING
STP Groep will only process your personal information in compliance with the law. Such laws vary across different territories and further specific information is available on request. In general, STP Groep will either process:
Based on your consent, for example to send you marketing messages about products and services in accordance with your interests and preferences, where such consent is required by law.
Where necessary for the performance of, or entry into, any contract we have with you, for example, to provide you with the Services you have subscribed – in that context, we need that information because otherwise we would not be able to provide the Services to you. For example, if we are required to verify your identity and you do not supply us with the relevant information, we may be unable to open an account for you.
Where STP Groep has a legitimate interest to process data, subject to such processing not overriding your own rights and freedoms in objecting to such processing. For example, to keep you informed about your use of the Services, improve, and develop the Services, conduct online advertising or other marketing activities, as well as manage and enforce any claim.
Where STP Groep has a legal obligation to collect, use and/or disclose your personal information or otherwise needs your personal information to protect your vital interests or those of another person. For example, when necessary to comply with the rules imposed by our or other applicable regulators; or
Exceptionally, we may share your information with a third-party when necessary, in the public interest, for example, when law enforcement agencies or other third parties with whom you may have had dealings request information to investigate a crime or otherwise a breach of third-party terms of business.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us via the Contact Us section below.
DO NOT TRACK
Some web browsers may send out “do not track” signals. However, there is no industry standard currently in place as to what websites and other online services should do on receipt of such signals. Should such a standard be developed, we will re-visit our policy, but currently we take no action on receipt of such signals.
COOKIES
Please also refer to our Cookie Statement for details on how we collect, use, or disclose information in respect of cookies. Otherwise, please Contact Us.
CHANGES TO OUR PRIVACY STATEMENT
We may, from time to time, change our privacy statement. If we make material changes to how we treat your information, we will notify you through a statement on this website/portal. The date the privacy statement was last modified is stated on this statement. Please ensure you periodically visit our website/portal and this privacy statement to check for any changes. However, if we are required by law to give you advance notice of any changes to this privacy statement and/or seek your consent to changes in our uses of your personal information, then we will do so.
LINKS TO THIRD-PARTY SITES
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow such a link, please note that these websites have their own privacy and cookies policies and STP Groep does not accept any responsibility or liability for these third-party websites.
GLOBAL STATEMENT
This statement is global in scope but is not intended to override any legal rights or prohibitions in any territory where such rights or prohibitions prevail. In such event, the rights and obligations set out in this statement will apply, subject only to amendment under any applicable local law having precedence.
CONTACT US
All comments, queries and requests relating to our use of your information are welcomed. If you wish to exercise any of your rights, you should complete our Dedicated Rights form. Alternatively, you may exercise your rights by contacting us on the details provided below. For further information as to the applicable STP Groep group companies to which this statement applies, you should write to the address below, marked FAQ Privacy Department or Contact Us.
Address: Beijerlandselaan 184B, 3074 ES Rotterdam, Netherlands Email: info@fidur.com