Privacy Policy Updated: 17/09/2020
Pxy Capital Limited (“PyxPro”, “We”, “Our” or “Us”) is an innovative cross-border payment service provider, and is recognised as a financial conduit for corporate merchants and their customers. This Privacy Notice describes Our data privacy practices and policies when you interact with Us. If Our practices and policies change, We will update this Privacy Notice.
PyxPro is committed to protect your data, privacy, personal and financial information, in accordance with the privacy and data protection regulation of the jurisdictions within which We operate.
Scope of this Privacy Notice (“Policy”)
This Privacy Notice applies when you interact with PyxPro, including all regions in the world.
For example, this Privacy Notice applies when you:
• Use PyxPro, either directly or through Our website or mobile applications;
• Interact with PyxPro on social media;
• Contact PyxPro’s office;
This Privacy Notice does not apply to the policies and practices of companies that are not related to PyxPro. We are not responsible for other company’s privacy policies and practices. We are not endorsing other company’s policies and practices if We provide a link to a third-party website.
We do not knowingly attempt to solicit or receive information from children or minors in accordance with any local law.
1. Why We collect and process Personal Information
We collect and process Personal Information so We can provide you with Our products and services on the best basis for you.
This includes:
• Processing your application;
• Providing you service with Our website and APP;
• Answering your inquiries;
• Identifying you in accordance with Our obligation under the applicable regulation and law, including Anti-Money Laundering and Counter Terrorism Financing Act;
• Performing administrative and operational tasks (including systems development and testing, staff training, and market or customer satisfaction research).
We also collect your Personal Information so that We can contact you and provide you with information about products and services that We believe may be of interest to you.
2. Who do We collect information about
Where reasonable and practical We will only collect your Personal Information directly from you. However, We may also collect information about you from third parties, such as a partner or spouse who contacts Us on your behalf, from Our contractors who supply services to Us, from advisers such as accountants or lawyers or from other organisations authorised by you.
If you provide Personal Information to Us about someone else, you must ensure that you are entitled to disclose that information to Us and that We can collect, use and disclose that information as set out in the Policy without having to take any further steps required under law (such as obtain that person’s consent). This means that if you provide Us with ‘Personal Information about someone else’, you must make sure that the individual concerned understands the matters set out in this Policy and has provided their consent to be bound by this Policy.
3. Personal Information and other information We may collect
PyxPro collects Personal Information Data. When you interact with Us We may collect Personal Information that identifies you as an individual or relates to you as an identifiable individual.
Personal Information We collect may include your:
• First and last name;
• Address;
• Contact information;
• Date of birth;
• Information to confirm your identity;
• Financial information (including business certificates, bank account information, accounting information and payment history, records and reasons thereof).
We may collect additional information, such as your country of birth or your government identification. Unless We specifically request it, please do not share with Us sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or any trade union membership).
Other Information
We may also collect other information that by itself doesn’t identify you. This may include:
• Browser and device information;
• Mobile application usage data;
• Details of the transactions you carry out when using Our Services, including geographic location from which the transaction originates;
• Information collected through cookies, pixel tags and other technologies;
• Demographic information and other information provided by you that does not reveal your specific identity;
• Information that has been aggregated in a manner that it no longer reveals your specific identity. We may merge Personal Information and other information. We will treat this information as Personal Information if We are required to by law;
• Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our website or App (including date and time); products 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 page and any phone number used to call Our Customer Support number.
4. How do We collect and protect your Personal Information
We collect Personal Information directly from you, and from other sources. We and Our service providers collect Personal Information in a variety of ways, including:
Directly from you: when you interact with Us when
• you contact Us by telephone, email or via Our App or via Our website;
• you create or update a user profile that includes Personal Information such as your name and contact details;
• you apply for one of Our products or services;
• you apply for employment with Us.
For example, We collect Personal Information from you if you use Our services, call Our call centre, or apply to become an agent. If you provide information about someone else, you represent that you have permission to do so.
Indirectly from other sources: such as public databases, joint marketing partners, social media platforms (including from people with whom you are connected), and from other third parties. If you connect your PyxPro profile to your social media account(s), some Personal Information from your social media account will be shared with Us, which may include Personal Information that is part of your profile or your connections’ profiles in social media.
How We Collect Other Information
We collect other information in a variety of ways, including:
• Through your browser or device: most browsers collect certain information automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, or internet browser type and version. We use this information to ensure that the services We provide function properly on a specific device.
• Through your IP address: An IP (Internet Protocol) address is a unique identifier that electronic devices use to identify and communicate with each other on the internet. We may identify your IP address and log it into Our server log files when you access Our websites or mobile applications, along with the time and page(s) you visit. When you visit Our website, We may view the IP address of the computer or device you use to connect to the internet. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for a variety of reasons, such as calculating usage levels, diagnosing server problems and administering the services.
• Through the PyxPro mobile application: if you download and use a PyxPro mobile application (App), We may track and collect usage data, such as the date and time your device accesses Our servers and which information and files have been downloaded.
• From your physical location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about advertisements you view and other information We collect, with Our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. You may be able to allow or deny such uses and/or sharing of your device’s location, but if you do, We and/or Our marketing partners may not be able to provide you with personalized services and content.
5. How do We use Personal Information and other information
We will only use your Personal Information for the purpose for which it has been provided, for reasonably related secondary purposes, any other purpose you have consented to and any other purpose permitted under the Privacy Act.
The ways that We use your Personal Information may include:
• Complete your transactions, respond to your questions, and provide you with customer service;
• Send you transactional and other administrative messages;
• Personalize your experience when you use Our services;
• Invite you to participate in contests and similar promotions, and to administer these activities, which may have additional notices about how We use and disclose your information;
• Operate and grow Our business (e.g., conduct data analysis; audit Our activities; develop new products; enhance, improve and modify Our services; identify usage trends; determine the effectiveness of Our promotional campaigns);
• Monitor and prevent fraud, money laundering, abuse, and other actual and potential prohibited or illegal activities;
• Meet legal, auditing, regulatory, insurance, security and processing requirements;
• Report to credit bureaus;
• Respond to court orders and legal investigations;
• Deliver marketing communications to you about Our services and other companies’ services, such as offers or incentives that We believe may be of interest to you. These marketing communications may come from Us directly, or through Our affiliates or third parties, including Our agents who facilitate transactions on Our behalf;
• Comply with applicable laws, which may include laws outside your country of residence;
• Respond to requests from public and government authorities, which may include authorities outside your country of residence;
• Cooperate with law enforcement, or for other legal reasons;
• Enforce Our terms and conditions;
• Protect Our rights, privacy, safety or property, and/or that of Our affiliates, you or others. We may also use information in other ways with your consent or as permitted or required by applicable law.
6. Where We store your data and how We retain it
We keep information only as long as necessary. We keep information only if necessary and for the purpose it was initially collected, or for a longer retention period as required or permitted by law. Once information is no longer needed for its initial purpose, it will be deleted in accordance with Our policies and procedures.
7. Disclosure of your information
PyxPro shares and disclose information with Our affiliates, vendors, and other third parties. We share and disclose information with:
• Our subsidiaries of PyxPro and affiliated entities for the purposes described in this Privacy Notice (Pyx Capital Limited is the party responsible for the management of jointly-used Personal Information);
• Our vendors or contractors that provide Us with services related to information technology, such as website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, and email delivery;
• Our vendors that provide Us with services related to Our marketing communications and campaigns, consistent with your choices, including any applicable choices We provide for you to opt into such sharing;
• Our vendors that assist Us with any contests and other promotions;
• Your social media connections, other website users and your social media account providers if you connect your PyxPro profile with your social media account(s);
• Other third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of Our business, assets or stock, or in any bankruptcy or similar proceedings.
You consent to Us disclosing your information to such entities without obtaining your consent on a case by case basis.
8. Jurisdiction and Cross-Border Data Transfers
If you are a resident of the European Economic Area (EEA), when you give Us your Personal Information, We will protect it in accordance with the General Data Protection Regulation (GDPR). We will also comply with the GDPR if We process your Personal Information in the EEA. For GDPR purposes, We are the ‘controller’ of your information.
We are based in and operate from the United Kingdom. When you interact with Us, your information may be sent to a country other than your own, including both those from within and outside of the EEA, for processing and storage. You also understand and agree that data protection rules of other countries may be different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your information.
Personal Information collected in the European Economic Area is controlled by PyxPro. PyxPro maintains adequate measures, such as Model Contractual Clauses approved by the European Commission, for the international transfer of Personal Information collected in the EEA and Switzerland. Please contact Us if you would like more information.
9. Data security
We are committed to using appropriate organizational, technical and administrative measures to protect personal and other information. All information We collect is stored on Our secure servers or severs provided by service providers to Us. Any payment transactions will be encrypted to a high and acceptable security standard.
As you will understand, no data transmission or storage system can be guaranteed to be 100% secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data during transmission, and any transmission is therefore at your own risk. Once We have received your information, We will use strict procedures and security measures to prevent unauthorised access to Our utmost ability.
10. Marketing communication
We may liaise with third parties to deliver advertising and marketing messages that we believe may interest you. These companies may place or recognise a unique cookie on your browser (including pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. For more information, and to learn how to opt out of these technologies, you may download the ‘AppChoices’ app to opt-out in mobile apps.
11. Cookies
Some of the Cookies used by Us will be automatically deleted from your hard drive at the end of your browser session (Session Cookies). We also use Cookies which remain on your hard drive for a certain period after the end of your browser session (Persistent Cookies). Then on your next visit, the country and language you selected on your last visit to Our Website will immediately be recognised. These Persistent Cookies will be stored on your hard drive and deleted by the browser after the prescribed period. These Cookies may also include Cookies from third-party providers (Third-Party Cookies).
12. Your legal right
Your Marketing Choices
You have control over the marketing communications you receive from Us. You can opt-out from receiving marketing communications from Us by:
• Updating your choices on your PyxPro profile;
• Clicking on the “unsubscribe” link at the bottom of any PyxPro marketing email;
• Replying “STOP” to a text or SMS message;
• Contacting Us at: info@pyxpro.com, We will respond to your request as soon as reasonably practicable. Please note that if you opt-out of receiving marketing related emails from Us, We may still send you transactional or administrative messages.
Accessing Your Personal Information
You can access, change or suppress your Personal Information. You can review, correct, update, suppress, restrict or delete Personal Information that you have given to Us, or receive an electronic copy of your Personal Information to transmit it to another company (to the extent provided to you by applicable law), by contacting Us at: info@pyxpro.com. We will respond to your request without undue delay. For your protection, We may need to verify your identity before implementing your request.
Please note that We may need to keep certain information for recordkeeping purposes or for regulatory compliance. There may also be residual information that will remain within Our databases and other records, which will not be removed.
13. Further enquiries and complaints
Generally: Pyx Capital Limited, is the company responsible for the collection, use and disclosure of your Personal Information under this Privacy Notice.
If you have questions about this Privacy Notice or Our privacy practices, or would like to request access to your information, please contact Our Data Protection Officer at 85 Great Portland Street, London W1W 7LT, United Kingdom, or;
In the EEA: If you live in the EEA and have questions about this Privacy Notice or Our privacy practices, or would like to access your information, please contact Our Data Protection Officer by email to info@pyxpro.com.
You also have the right to lodge a complaint with a supervisory or competent authority responsible for your country or region.
PyxPro is committed to protect your data, privacy, personal and financial information, in accordance with the privacy and data protection regulation of the jurisdictions within which We operate.
Scope of this Privacy Notice (“Policy”)
This Privacy Notice applies when you interact with PyxPro, including all regions in the world.
For example, this Privacy Notice applies when you:
• Use PyxPro, either directly or through Our website or mobile applications;
• Interact with PyxPro on social media;
• Contact PyxPro’s office;
This Privacy Notice does not apply to the policies and practices of companies that are not related to PyxPro. We are not responsible for other company’s privacy policies and practices. We are not endorsing other company’s policies and practices if We provide a link to a third-party website.
We do not knowingly attempt to solicit or receive information from children or minors in accordance with any local law.
1. Why We collect and process Personal Information
We collect and process Personal Information so We can provide you with Our products and services on the best basis for you.
This includes:
• Processing your application;
• Providing you service with Our website and APP;
• Answering your inquiries;
• Identifying you in accordance with Our obligation under the applicable regulation and law, including Anti-Money Laundering and Counter Terrorism Financing Act;
• Performing administrative and operational tasks (including systems development and testing, staff training, and market or customer satisfaction research).
We also collect your Personal Information so that We can contact you and provide you with information about products and services that We believe may be of interest to you.
2. Who do We collect information about
Where reasonable and practical We will only collect your Personal Information directly from you. However, We may also collect information about you from third parties, such as a partner or spouse who contacts Us on your behalf, from Our contractors who supply services to Us, from advisers such as accountants or lawyers or from other organisations authorised by you.
If you provide Personal Information to Us about someone else, you must ensure that you are entitled to disclose that information to Us and that We can collect, use and disclose that information as set out in the Policy without having to take any further steps required under law (such as obtain that person’s consent). This means that if you provide Us with ‘Personal Information about someone else’, you must make sure that the individual concerned understands the matters set out in this Policy and has provided their consent to be bound by this Policy.
3. Personal Information and other information We may collect
PyxPro collects Personal Information Data. When you interact with Us We may collect Personal Information that identifies you as an individual or relates to you as an identifiable individual.
Personal Information We collect may include your:
• First and last name;
• Address;
• Contact information;
• Date of birth;
• Information to confirm your identity;
• Financial information (including business certificates, bank account information, accounting information and payment history, records and reasons thereof).
We may collect additional information, such as your country of birth or your government identification. Unless We specifically request it, please do not share with Us sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or any trade union membership).
Other Information
We may also collect other information that by itself doesn’t identify you. This may include:
• Browser and device information;
• Mobile application usage data;
• Details of the transactions you carry out when using Our Services, including geographic location from which the transaction originates;
• Information collected through cookies, pixel tags and other technologies;
• Demographic information and other information provided by you that does not reveal your specific identity;
• Information that has been aggregated in a manner that it no longer reveals your specific identity. We may merge Personal Information and other information. We will treat this information as Personal Information if We are required to by law;
• Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our website or App (including date and time); products 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 page and any phone number used to call Our Customer Support number.
4. How do We collect and protect your Personal Information
We collect Personal Information directly from you, and from other sources. We and Our service providers collect Personal Information in a variety of ways, including:
Directly from you: when you interact with Us when
• you contact Us by telephone, email or via Our App or via Our website;
• you create or update a user profile that includes Personal Information such as your name and contact details;
• you apply for one of Our products or services;
• you apply for employment with Us.
For example, We collect Personal Information from you if you use Our services, call Our call centre, or apply to become an agent. If you provide information about someone else, you represent that you have permission to do so.
Indirectly from other sources: such as public databases, joint marketing partners, social media platforms (including from people with whom you are connected), and from other third parties. If you connect your PyxPro profile to your social media account(s), some Personal Information from your social media account will be shared with Us, which may include Personal Information that is part of your profile or your connections’ profiles in social media.
How We Collect Other Information
We collect other information in a variety of ways, including:
• Through your browser or device: most browsers collect certain information automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, or internet browser type and version. We use this information to ensure that the services We provide function properly on a specific device.
• Through your IP address: An IP (Internet Protocol) address is a unique identifier that electronic devices use to identify and communicate with each other on the internet. We may identify your IP address and log it into Our server log files when you access Our websites or mobile applications, along with the time and page(s) you visit. When you visit Our website, We may view the IP address of the computer or device you use to connect to the internet. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for a variety of reasons, such as calculating usage levels, diagnosing server problems and administering the services.
• Through the PyxPro mobile application: if you download and use a PyxPro mobile application (App), We may track and collect usage data, such as the date and time your device accesses Our servers and which information and files have been downloaded.
• From your physical location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about advertisements you view and other information We collect, with Our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. You may be able to allow or deny such uses and/or sharing of your device’s location, but if you do, We and/or Our marketing partners may not be able to provide you with personalized services and content.
5. How do We use Personal Information and other information
We will only use your Personal Information for the purpose for which it has been provided, for reasonably related secondary purposes, any other purpose you have consented to and any other purpose permitted under the Privacy Act.
The ways that We use your Personal Information may include:
• Complete your transactions, respond to your questions, and provide you with customer service;
• Send you transactional and other administrative messages;
• Personalize your experience when you use Our services;
• Invite you to participate in contests and similar promotions, and to administer these activities, which may have additional notices about how We use and disclose your information;
• Operate and grow Our business (e.g., conduct data analysis; audit Our activities; develop new products; enhance, improve and modify Our services; identify usage trends; determine the effectiveness of Our promotional campaigns);
• Monitor and prevent fraud, money laundering, abuse, and other actual and potential prohibited or illegal activities;
• Meet legal, auditing, regulatory, insurance, security and processing requirements;
• Report to credit bureaus;
• Respond to court orders and legal investigations;
• Deliver marketing communications to you about Our services and other companies’ services, such as offers or incentives that We believe may be of interest to you. These marketing communications may come from Us directly, or through Our affiliates or third parties, including Our agents who facilitate transactions on Our behalf;
• Comply with applicable laws, which may include laws outside your country of residence;
• Respond to requests from public and government authorities, which may include authorities outside your country of residence;
• Cooperate with law enforcement, or for other legal reasons;
• Enforce Our terms and conditions;
• Protect Our rights, privacy, safety or property, and/or that of Our affiliates, you or others. We may also use information in other ways with your consent or as permitted or required by applicable law.
6. Where We store your data and how We retain it
We keep information only as long as necessary. We keep information only if necessary and for the purpose it was initially collected, or for a longer retention period as required or permitted by law. Once information is no longer needed for its initial purpose, it will be deleted in accordance with Our policies and procedures.
7. Disclosure of your information
PyxPro shares and disclose information with Our affiliates, vendors, and other third parties. We share and disclose information with:
• Our subsidiaries of PyxPro and affiliated entities for the purposes described in this Privacy Notice (Pyx Capital Limited is the party responsible for the management of jointly-used Personal Information);
• Our vendors or contractors that provide Us with services related to information technology, such as website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, and email delivery;
• Our vendors that provide Us with services related to Our marketing communications and campaigns, consistent with your choices, including any applicable choices We provide for you to opt into such sharing;
• Our vendors that assist Us with any contests and other promotions;
• Your social media connections, other website users and your social media account providers if you connect your PyxPro profile with your social media account(s);
• Other third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of Our business, assets or stock, or in any bankruptcy or similar proceedings.
You consent to Us disclosing your information to such entities without obtaining your consent on a case by case basis.
8. Jurisdiction and Cross-Border Data Transfers
If you are a resident of the European Economic Area (EEA), when you give Us your Personal Information, We will protect it in accordance with the General Data Protection Regulation (GDPR). We will also comply with the GDPR if We process your Personal Information in the EEA. For GDPR purposes, We are the ‘controller’ of your information.
We are based in and operate from the United Kingdom. When you interact with Us, your information may be sent to a country other than your own, including both those from within and outside of the EEA, for processing and storage. You also understand and agree that data protection rules of other countries may be different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your information.
Personal Information collected in the European Economic Area is controlled by PyxPro. PyxPro maintains adequate measures, such as Model Contractual Clauses approved by the European Commission, for the international transfer of Personal Information collected in the EEA and Switzerland. Please contact Us if you would like more information.
9. Data security
We are committed to using appropriate organizational, technical and administrative measures to protect personal and other information. All information We collect is stored on Our secure servers or severs provided by service providers to Us. Any payment transactions will be encrypted to a high and acceptable security standard.
As you will understand, no data transmission or storage system can be guaranteed to be 100% secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data during transmission, and any transmission is therefore at your own risk. Once We have received your information, We will use strict procedures and security measures to prevent unauthorised access to Our utmost ability.
10. Marketing communication
We may liaise with third parties to deliver advertising and marketing messages that we believe may interest you. These companies may place or recognise a unique cookie on your browser (including pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. For more information, and to learn how to opt out of these technologies, you may download the ‘AppChoices’ app to opt-out in mobile apps.
11. Cookies
Some of the Cookies used by Us will be automatically deleted from your hard drive at the end of your browser session (Session Cookies). We also use Cookies which remain on your hard drive for a certain period after the end of your browser session (Persistent Cookies). Then on your next visit, the country and language you selected on your last visit to Our Website will immediately be recognised. These Persistent Cookies will be stored on your hard drive and deleted by the browser after the prescribed period. These Cookies may also include Cookies from third-party providers (Third-Party Cookies).
12. Your legal right
Your Marketing Choices
You have control over the marketing communications you receive from Us. You can opt-out from receiving marketing communications from Us by:
• Updating your choices on your PyxPro profile;
• Clicking on the “unsubscribe” link at the bottom of any PyxPro marketing email;
• Replying “STOP” to a text or SMS message;
• Contacting Us at: info@pyxpro.com, We will respond to your request as soon as reasonably practicable. Please note that if you opt-out of receiving marketing related emails from Us, We may still send you transactional or administrative messages.
Accessing Your Personal Information
You can access, change or suppress your Personal Information. You can review, correct, update, suppress, restrict or delete Personal Information that you have given to Us, or receive an electronic copy of your Personal Information to transmit it to another company (to the extent provided to you by applicable law), by contacting Us at: info@pyxpro.com. We will respond to your request without undue delay. For your protection, We may need to verify your identity before implementing your request.
Please note that We may need to keep certain information for recordkeeping purposes or for regulatory compliance. There may also be residual information that will remain within Our databases and other records, which will not be removed.
13. Further enquiries and complaints
Generally: Pyx Capital Limited, is the company responsible for the collection, use and disclosure of your Personal Information under this Privacy Notice.
If you have questions about this Privacy Notice or Our privacy practices, or would like to request access to your information, please contact Our Data Protection Officer at 85 Great Portland Street, London W1W 7LT, United Kingdom, or;
In the EEA: If you live in the EEA and have questions about this Privacy Notice or Our privacy practices, or would like to access your information, please contact Our Data Protection Officer by email to info@pyxpro.com.
You also have the right to lodge a complaint with a supervisory or competent authority responsible for your country or region.