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EPS & EPAPL Privacy Policy

  • Electronic Payment And Services Private Limited (“EPS”) is in the business of providing self-service technology (including automated teller machines) and related services to its customers within India, as well as Electronic Payment Australia Pty. Ltd. (“EPAPL”), is a wholly owned subsidiary of EPS. Based out of Sydney, Australia providing a comprehensive suite of payment solutions and services that cater to ATM, PoS, E-commerce and all other digital mediums of transactions. We have our Privacy Policy to address the requirements of the European Union’s General Data Protection Regulation, which goes into effect on May 25, 2018.
  • We have also attempted to be more transparent about how we Process your Personal Data.

    If you have any questions about the to our Privacy Policy or your rights, please contact us at info@electronicpay.in.

    EPS and EPAPL are committed to protecting the confidentiality and integrity of Personal Data (as defined below) about you that we Process (as defined below), including Personal Data to which EPS and EPAPL has access in connection with the provision of products and services to our customers (in this Privacy Policy, “you” includes any individual about whom EPS or EPAPL collects, uses, or discloses Personal Data). EPS and EPAPL takes reasonable and appropriate steps to safeguard Personal Data in accordance with the applicable laws of the countries in which we conduct business and our contractual requirements.

    Scope of this Privacy Policy

    This Privacy Policy applies to any Personal Data that EPS and EPAPL Process regardless of how or where that information was obtained, or where it is stored or used, except in the following circumstances. This Privacy Policy does not apply to Contract Data (as defined below), except where specifically noted. This Privacy Policy also does not apply to a supplement to this Privacy Policy or to a separate Privacy Notice you receive from EPS and EPAPL, where that supplement or separate notice contradicts this Privacy Policy. Finally, this Privacy Policy does not apply to a contract EPS and EPAPL has executed with you, to the extent the terms of the contract conflict with this Privacy Policy.

    Definitions

    "Contract Data" means Personal Data about our customers' customers or our customers' personnel that EPS or EPAPL Processes in connection with providing products and services to a customer under a customer contract. Contract Data is a subset of "Controller" means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

    "Personal Data" means information relating to an identified or identifiable natural person to the extent such information is afforded the protection of law. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the individual’s physical, physiological, mental, economic, cultural, or social identity.

    "Process" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, blocking, erasure, or destruction.

    "Processor" means a natural or legal person, public authority, agency or other body which Processes Personal Data on behalf of a Controller.

    "Special Categories" means, to the extent designated under applicable law, Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

    EPS and EPAPL Obligations with Respect to Contract Data

    When we Process Personal Data solely in the performance of our customer contracts, EPS and EPAPL acts as a Processor and relies on its customers to comply with their obligations to you under the law. The relevant EPS or EPAPL customer’s privacy policy, and not this Privacy Policy, applies to such Processing, and our obligations to the customer are set forth in our contract with them.

    Collection of Personal Data

    The Personal Data EPS and EPAPL may collect about you includes, but is not limited to, user IDs and passwords; demographic information; contact details, such as your name, address, email address, or telephone number; geo-location data; IP address; machine address or education or employment data.

    You may provide Personal Data to EPS and EPAPL in a variety of ways, such as by registering for an online account or event, joining a mailing list, purchasing a product or service, applying for employment, filling out an information form, or otherwise contacting us with a question, comment, or request. Additionally, EPS and EPAPL may collect information about you or obtain Personal Data about you from third parties for the purposes of providing you with information about EPS and EPAPL products and services that may be of interest to you, or to take steps to maintain the accuracy of the information we have about you. EPS and EPAPL may also use certain technologies to collect information about you while you are visiting an EPS or EPAPL website, as described below.

    EPS and EPAPL will obtain Personal Data about you only by fair and lawful means, and will take steps designed to be transparent with you about the purposes for which such information is being collected and how EPS and EPAPL Processes that data.

    With respect to Contract Data, it is our customers’ responsibility to ensure that EPS’s or EPAPL’s Processing of Personal Data we receive under our contract with them is consistent with the terms of our customers’ privacy policies.

    Use of Personal Data

    EPS and EPAPL will use Personal Data covered by this Privacy Policy in a manner that is consistent with applicable law and:

  • With your consent, where consent is required by law. You may always withdraw your consent to this processing at any time, however, doing so will not affect the lawfulness of EPS or EPAPL’s processing before your withdrawal of consent. Once you withdraw consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. In case we processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such marketing purposes.; or
  • Where reasonably necessary to fulfill EPS or EPAPL’s business needs, including to:
  • Perform a contract with you or take steps at your request prior to entering into a contract;
  • Comply with a regulatory or legal obligation;
  • Protect your vital interests or that of another natural person;
  • Perform a task carried out in the public interest;
  • Further a legitimate interest of EPS and EPAPL or a third party including but not limited to:
  • Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
  • Protecting EPS and EPAPL personnel, property and assets from threats or harm including to EPS and EPAPL’s information technology infrastructure, Intellectual property, or goodwill or reputation;
  • Ensuring compliance with relevant corporate policies;
  • Optimizing utilization of global corporate resources including the administration of business transactions, personnel and information technology systems.

    With respect to Special Categories of Personal Data, EPS and EPAPL may Process such information in a manner that is consistent with applicable law and:

  • With your explicit consent for one or more specified purposes. You may always withdraw your consent to this processing at any time, however, doing so will not affect the lawfulness of EPS or EPAPL’s processing before your withdrawal of consent. Once you withdraw consent, we will no longer process your information unless there is a lawful reason for us to do so. One example where we may be permitted by the law to continue processing your information would be to pursue or defend a legal claim; or
  • Where Processing:
  • is necessary to carry out our obligations and exercise our rights as an employer; or
  • is necessary to protect your vital interests or those of another person, and where you are physically or legally incapable of giving consent; or
  • relates to Personal Data that you have manifestly made public; or
  • is necessary for EPS or EPAPL to pursue or defend legal claims or where a court compels us to do so; or
  • is necessary for reasons of substantial public interest; or
  • is necessary for the purposes of the assessment of your working capacity.

    In most cases, we will seek Personal Data from you to provide you with information, products or services or for the purposes of entering into or performing a contract. At other times, we may be required by law to seek the Personal Data. In either event, we will strive to be transparent with you as to the purposes of collection and whether providing the information is voluntary and what the possible consequences would be if you chose not to do so.

    EPS or EPAPL may combine Personal Data it obtains about you from various other sources to help us improve its overall accuracy and completeness, and to help us better tailor our interactions with you.

    EPS and EPAPL will retain Personal Data only for so long as it is necessary to support the overall purpose(s) for which EPS and EPAPL collected such information plus any further period as may be required or reasonably necessary for record keeping, analysis or to meet legal or regulatory requirements. We take steps to minimize access, use and retention of Personal Data for such ongoing retention to what is reasonably necessary. To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    EPS’s or EPAPL’s use may include, but is not limited to, making sales calls, sending marketing communications, delivering or completing requested services or transactions, and tracking and analyzing a series of transactions.

    EPS and EPAPL will use Contract Data consistent with applicable contractual obligations and applicable law. EPS and EPAPL also may use Contract Data to facilitate compliance with regulatory and legal requirements.

    For anonymised or aggregated data which was formerly Personal Data but which can no longer identify individuals, EPS and EPAPL may conduct research and development, statistical, trend or pattern analysis in order to continuously improve our products, services processes and security procedures.

    Sales and Marketing - EPS and EPAPL may use your Personal Data for sales and marketing purposes, including contacting you for feedback in customer satisfaction surveys or for market research purposes, providing you with marketing literature on products and services, notifying you of events, and providing you with information about EPS and EPAPL. You may always change your privacy preferences as set forth below. From time to time, EPS and EPAPL may co-brand an offering or a communication with a third party, which may also collect your Personal Data. In such cases, the use of your Personal Data by such third parties is covered by their respective privacy policies, and not this Privacy Policy. In those cases where you choose to forward a page to another individual (where such option is available), EPS or EPAPL may request certain Personal Data about that individual to complete your request, such as their name and e-mail address, but EPS or EPAPL will not make further use of such information.

    Social Networking Tools - If EPS and EPAPL uses social networking tools to provide information to you, your information will be governed by the terms of use and the privacy policy for the applicable social networking tool.

    Fulfilling Business Transactions - EPS and EPAPL may use your Personal Data to fulfil business transaction requests with you or your organization. With respect to our customers, such requests may include, but are not limited to, providing products or services including delivering notifications of product issues, fixes or updates, or contacting you in response to your questions, comments, or requests. With respect to our suppliers, such requests may include issuing purchase orders, receiving invoices, or providing other information such as forecasts. If, in providing service or support (including support to assist you with the use of our websites or applications), we engage you telephonically or via electronic communications through tools such as email or online chat, we may monitor or record our interactions for purposes of quality assurance, training, or to document the details of the interaction or transaction.

    Recruitment - If you seek employment with EPS or EPAPL, you may provide us with information about yourself, such as a resume. We may utilize automated processing techniques for candidate applications for qualitative scoring or ranking to optimize the efficiency of our recruiting practices. In such cases, however, this processing is overseen by our Human Resources personnel. We may use this information throughout EPS and EPAPL to consider you for employment purposes, and may keep your information on file for future consideration, to support EPS’s or EPAPL’s compliance with applicable legal requirements, and as otherwise set forth in this Privacy Policy or in a separate notice that may be provided to you, to the extent such notice conflicts with this Privacy Policy.

    Transfers

    EPS and EPAPL has presence globally with global operations, partners and suppliers. Where it is necessary for the efficient and effective performance of a business transaction or the fulfilment of one of the uses of Personal Data outlined above, EPS or EPAPL may need to transfer Personal Data from the country of collection to another country or even in some cases, ‘onward transfers’. Where such a transfer is made from one country or territory to another which is not deemed by the first exporting country (“Exporting Country”) to offer an adequate level of protection to the rights and freedoms of data subjects, EPS’s or EPAPL’s policy is to do so on the basis of contractual controls between the relevant group companies, partners or suppliers designed to ensure that substantially the same level of protection is afforded to the Personal Data as in the Exporting Country. EPS’s or EPAPL’s contractual safeguards are based on the ‘standard contractual clauses’ issued by the European Commission or other data protection regulatory authority as appropriate for the law of the Exporting Country.

    Disclosure of Personal Data

    We may share Personal Data (including Contract Data) within EPS or EPAPL and including by way of transfer it to countries around the world in which we operate in connection with the uses described in this Privacy Policy and in accordance with its terms.

    We may share Personal Data with third-party suppliers and service providers that help us Process Personal Data. Examples of categories of suppliers include: HR service providers (such as payroll providers, background verification providers, benefits providers, and document management providers), IT vendors, including security product providers, email providers and application providers, contingent workers, and consultants.

    It is EPS’s and EPAPL’s practice to enter into contracts with our suppliers and service providers that require them to handle your information in a manner consistent with EPS and EPAPL policy and applicable law.

    EPS and EPAPL also may provide information that identifies you at an individual level to third-party business partners, such as resellers. EPS and EPAPL does not, however, sell or rent such information to these third parties.

    From time to time, EPS and EPAPL may contemplate entering into various business development activities which may include the sale, purchase, merger, or reorganization of one or more of its businesses. These business development activities may require the disclosure of Personal Data to the prospective or actual purchaser(s). When such disclosures are required, EPS and EPAPL will seek appropriate protections of your Personal Data.

    In certain circumstances, EPS and EPAPL may use or release Personal Data to third parties when disclosure is required by law (e.g. statute, judicial proceeding, court order, or subpoena). We also reserve our right to use or provide your Personal Data to third parties, including law enforcement, auditors, consultants, and government officials, to protect EPS’s and EPAPL’s rights or property, and/or the rights or property of our customers, business partners, suppliers, or other third parties.

    Setting Your Privacy Preferences and Opting Out

    From time to time, you may sign up to receive information or access to EPS and EPAPL services, or where law permits, we may proactively provide you with information we believe may be of interest to you. In all cases, we will provide you with mechanisms to opt out of receiving such communications or services. In addition, you may indicate to us that you no longer wish to receive emailed marketing communications from us by following the unsubscribe instructions included in the email communications we may provide to you, and you may always contact us directly as set forth in this Privacy Policy.

    With respect to Contract Data, the EPS and EPAPL customer is responsible for obtaining consent and, where applicable, processing opt-out or unsubscribe requests.

    Accessing and Maintaining the Accuracy of Your Personal Data

    EPS and EPAPL strives to maintain the accuracy of any Personal Data we collect about you and to Process only the Personal Data that is relevant and limited to what is necessary for the purposes for which the information is Processed. We provide several mechanisms to allow you to:

  • Access Personal Data about you consistent with legal requirement. In addition, you may have the right in some cases to receive or have your Personal Data transferred to another party. Where permitted by law, EPS and EPAPL may charge a reasonable fee if we are required to provide information about you.
  • Request correction of your Personal Data where it is inaccurate. In some cases, EPS and EPAPL may provide self-service tools that enable you to update Personal Data about you.
  • Request deletion of your Personal Data where required by law.
  • Request restriction of Processing of your Personal Data where such requests are permitted by law. EPS and EPAPL will notify you before we begin to process any information about you that was restricted just prior to processing.

    You may use the contact mechanisms specified below to request that we update, correct, restrict or delete your Personal Data on file with us. In certain circumstances applicable law may permit EPS and EPAPL to deny such requests, for example where an access request is manifestly unfounded or excessive, in particular where it is repetitive, where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where the rights of other persons would be violated). You may appeal a denial by contacting EPS or EPAPL in the manner set forth in the Contact Us section of this Privacy Policy.

    Before acting on a request to do any of the foregoing, EPS and EPAPL will take reasonable steps to verify your identity.

    With respect to data controlled by third parties, such as Contract Data, the third party is responsible for maintaining the accuracy of the Personal Data it collects and Processes. Requests to access, correct, restrict or delete Personal Data controlled by third parties (such as Contract Data) must be directed to that third party.

    Right to Object to Processing

    We value the trust you place in us by sharing your Personal Data with us as we strive to improve our products, services and processes. If you have any concerns about the way in which we process your Personal Data, please contact us for clarification.

    If you are subject to certain laws, for example, the EU General Data Protection Regulation, you may also have specific rights to object to processing of Personal Data about you, for example, when we Process your Personal Data on the basis of the ‘legitimate interests’ grounds outlined above. We will respect your choice unless we have a compelling interest overriding your objection.

    Similarly, where we process your Personal Data for the purposes of direct marketing (including profiling to the extent that it is related to such direct marketing), you have the right at any time to object to such processing.

    Use of Automated Individual Decision Making including Statistical Analysis and Profiling

    EPS and EPAPL may use statistical and analytic techniques to support automated individual decision making including profiling for the purpose of improving the quality, performance or efficiency of our products, services or processes or to screen applicants for employment, to facilitate compliance with law or policy, or to protect our information technology infrastructure. We take reasonable steps to be transparent with you about the nature of that processing and to protect your rights and freedoms in cases where we use automated processing.

    Use of Cookies and Other Technologies

    As described in more detail below, EPS and EPAPL websites may employ a variety of tools to help us improve your experience on our websites and determine the effectiveness of certain of our marketing initiatives.

    Cookies - A cookie is a small element of data that a website can send to a web browser, which is then stored on the browser user’s computing device. We may use cookies, alone or in combination with other data we may collect from other technologies (such as server logs) to make our websites work or operate more efficiently, to personalize a user’s experience, or to make our websites more useful to our visitors. When EPS and EPAPL places a cookie on your device from an EPS or EPAPL domain, called a “first party cookie.” If a third party, such as an advertiser, places a cookie on your device, those cookies are called “third party cookies.” EPS’s and EPAPL’s Privacy Policy only applies to first party cookies.

    Where required by applicable law, EPS and EPAPL will only place cookies on your device with your consent (which you may withdraw at any time). Your consent may also be indicated by your internet browser’s settings if they are set to “automatically accept cookies.” Most browsers, however, permit users to change these settings either to refuse all cookies or to selectively accept them. If you would like to change your browser’s cookie settings, please refer to the online help offered with your browser or to your device manufacturer’s website. Please note, however, if you decide to turn off cookies, there may be some features of our websites that may not be available to you and some pages may not display properly.

    Other Technology EPS or EPAPL May Use to Improve Your Experience.

    EPS, EPAPL, and our service providers, may also use other technology to improve your experience. As described below, these technologies include analysis tools, log file information, web beacons, web links, and local shared objects.

    Analysis Tools - EPS and EPAPL may use analysis tools like Google Analytics or Adobe Analytics to help us analyse how visitors use our websites. Among other things, these tools use cookies to collect data about the number of visitors to the site, the web page that referred visitors to the site, and the pages that visitors view within the site. Both Google Analytics and Adobe Analytics use persistent cookies. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout. To opt out of Adobe Analytics, visit http://www.adobe.com/privacy/opt-out.html.

    Log File Information - EPS and EPAPL records log file information whenever you access our websites. Examples of log file information include your IP address, your browser type, the page from which you accessed our website, the pages you viewed while visiting our website, the last page you viewed before you exited our website, and the page you accessed after leaving our website. We use this data in the aggregate and do not use it to identify you individually.

    Web Beacons, Pixel Tags, Clear GIFs and other technologies - These technologies involve placing electronic (and usually transparent) images on a website or in an email. These images place certain information on your device such as cookies, the time and date of a page you viewed and the length of time you viewed the page, the IP address of the device that retrieved the image, the time the web beacon was viewed and for how long, and the type of browser that retrieved the image. We may use these technologies, for example, to determine whether you have opened or accessed links included in marketing communications from EPS or EPAPL. These technologies often work with cookies; therefore, if you do not want us to associate your cookie information with your visits to our website, you must turn off cookies in your browser.

    Web Links - Emails from EPS and EPAPL may contain links that are designed to take you to a web page after redirection through EPS’s or EPAPL’s servers (or those of its suppliers). We use the information we obtain during the redirection process to determine whether a particular marketing initiative is effective, and may collect information connected to your identity. If you do not want EPS and EPAPL to collect information about the links that you click, you can choose a text-based version of the message (if the option is available). You may also choose not to click the links we provide in the emails we send to you and search online for the relevant resource independently.

    Local Shared Objects (“Flash Cookies”) - EPS and EPAPL may use Adobe Flash Player® to deliver multimedia content, such as a video, to you. To improve your user experience, EPS and EPAPL may use Flash local shared objects (LSOs) – sometimes called “flash cookies” – to store your flash content information and preferences, similar to other types of cookies EPS and EPAPL employs. You can manage flash cookies by accessing the following link on Adobe’s website: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

    Online Advertising

    Third parties do not advertise on EPS’s or EPAPL’s websites. EPS and EPAPL, however, may contract with third parties who collect information about your online activities over time and across different websites (including EPS and EPAPL websites). These third parties use cookies or web beacons across multiple websites, including EPS’s and EPAPL’s websites, to collect certain information about you to provide you with targeted ads based on your interests. We engage with these third parties to help us deliver targeted advertisements about EPS and EPAPL on other websites you visit. If we need to facilitate these third parties to place cookies on your device to enable this functionality, we will do so in accordance with this Privacy Policy. However, the third parties’ collection, use and disclosures of your information will be governed by their own privacy policies and statements. You have several choices to control the delivery of targeted ads to you by EPS and EPAPL.

    You may turn off cookies in your browser. For more information about this choice, please refer to the “Use of Cookies and Other Technologies” section of this Privacy Policy.

    Some browsers permit users to adjust browser settings or may contain add-ons to help you manage your ad choices. For more information about this choice, please refer to the online help offered with your browser or to the device manufacturer’s website.

    You may opt out of third parties’ advertising networks. We have provided the following information to help you with this choice:

    The Network Alliance Initiative and the Digital Advertising Alliance websites offer opt-out tools to assist you in managing your choices for participating companies. For more information about these tools please visit the NAI Opt-Out Page and the DAA Opt-Out Page.

    You may opt out of Google’s use of cookies by visiting Google’s AdSettings.

    You may opt out of DoubleClick’s use of cookies by visiting the DoubleClick Opt-Out Page or the NAI Opt-Out Page.

    Please note that, even if you exercise your choices, you may still receive generic, non-targeted ads from EPS and EPAPL.

    EPS and EPAPL websites do not respond to Web browser “do not track” browser header (or equivalent). If we do so in the future, we will describe how we do so in this Privacy Policy. If, however, your Web browser is set so as not to accept cookies, your use of our websites will not be tracked.

    Protection of Your Personal Data

    EPS and EPAPL takes data security seriously. We have implemented reasonable and appropriate physical, technical, and organizational measures that are designed to protect Personal Data covered by this Privacy Policy, including Contract Data, from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. EPS and EPAPL is not responsible for, nor can it guarantee, the security of any Personal Data transmitted over the Internet. Likewise, there is no guarantee that our physical, technical, or organizational security measures are fool proof. It is your responsibility to protect the security of your login information.

    Children's Information

    EPS’s and EPAPL’s applications and websites are not directed to, nor do we knowingly collect Personal Data from, children under the age of 16. By your use of our websites you affirm that you are at least 16 years of age. EPS and EPAPL does not knowingly solicit data from or market to children under the age of 16. If you are a parent or a guardian, and you believe your child has provided EPS and EPAPL with Personal Data without your consent, please contact us.

    Changes to This Privacy Policy

    We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our website. When we make any revisions that materially change the ways in which we use or share the Personal Data previously collected from you, we will give you the opportunity to consent to such changes before applying them to that Personal Data.

    Changing Your Preferences and Contacting Us

    You may change your marketing preferences by contacting us.

    We want to address any concerns you may have. You may send any comments or questions regarding this Privacy Policy or EPS’s or EPAPL’s handling of your Personal Data by email to info@electronicpay.in, or by mail to:

    ELECTRONIC PAYMENT AND SERVICES PVT. LTD.

    Unit No 302-303, A Wing, Supreme Business Park, Supreme City, Hiranandani Garden, Behind Lake Castle & Avalon , Powai , Mumbai - 400076

    or

    ELECTRONIC PAYMENT AUSTRALIA PTY LIMITED,

    Suite 102, 33 Lexington Drive, “Norwest Business Park”, Bella Vista, New South Wales, Australia 2153

    If EPS and EPAPL does not satisfactorily address your concerns and you are subject to the European Union’s General Protection Regulation, you have the right to lodge a complaint with your Supervisory Authority.

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