Version 1.0

TPML Privacy Policy

This policy explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

TPML is committed to safeguarding the privacy of your information. By “your data”, "your personal data”, and “your information” we mean any personal data about you which you or third parties provide to us.

We may change this Policy from time to time so please check this page regularly to ensure that you’re happy with any changes.

Who are we?
Transact Payments Malta Limited (“TPML”, “we”, “our” or “us”) is the issuer of your card and is the Data Controller for the personal data which you provide to us in relation to the card only. TPML is a private limited liability company incorporated and registered in Malta with company registration number C91879 and registered address at Vault 14, Level 2, Valletta Waterfront, Floriana, FRN 1914, Malta. TPML is authorised by the Malta Financial Services Authority as an Electronic Money Institution.

Yokoy GmbH (“Yokoy”) is the Program Manager for your card program and is the Data Controller for any personal data which you provide which is not related to the card. Yokoy is incorporated and registered in Austria with registered office at Wallgasse 21/12, 1060 Vienna.

How do we collect your personal data?
We collect information from you when you apply online or via a mobile application for a payments card which is issued by us. We also collect information when you use your card to make transactions. We also obtain information from third parties (such as fraud prevention agencies) who may check your personal data against any information listed on an Electoral Register and/or other databases.

On what legal basis do we process your personal data?
Contract
Your provision of your personal data and our processing of that data is necessary for each of us to carry out our obligations under the contract (known as the Cardholder Agreement or Cardholder Terms & Conditions or similar) which we enter into when you sign up for our payment services. At times, the processing may be necessary so that we can take certain steps, at your request, prior to entering into that contract, such as verifying your details or eligibility for the payment services. If you fail to provide the personal data which we request, we cannot enter into a contract to provide payment services to you or will take steps to terminate any contract which we have entered into with you.

Legal/Regulatory
We may also process your personal data to comply with our legal or regulatory obligations.

Legitimate Interests
We, or a third party, may have a legitimate interest to process your personal data, for example:

  1. To analyse and improve the security of our business;
  2. To anonymise personal data and subsequently use anonymized information.


What type of personal data is collected from you?
When you apply for a card, we, or our partners on our behalf, collect the following information from you: full name, physical address, email address, mobile phone number, phone number, date of birth, gender, login details, IP address, identity and address verification documents.

When you use your card to make transactions, we store that transactional and financial information. This includes the date, amount, currency, card number, card name, account balances and name of the merchant, creditor or supplier (for example a supermarket or retailer). We also collect information relating to the payments which are made to/from your account. 

How is your personal data used?
We use your personal data to:


Who do we share your information with?
When we use third party service providers, we have a contract in place that requires them to keep your information secure and confidential.

We pass your information to the following categories of entity: 


Sending personal data overseas
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:


These transfers are subject to special rules under European and Malta data protection law.

These non-EEA countries do not have the same data protection laws as Malta and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. We will send your data to countries where the European Commission has made an adequacy decision, meaning that it has ruled that the legislative framework in the country provides an adequate level of data protection for your personal information. You can find out more about this here.

Where we send your data to a country where the European Commission has not made an adequacy decision, our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses, please go to the European Commission’s website.
 
If you would like further information please contact our Data Protection Officer on the details below.

How long do we store your personal data?
We will store your information for a period of five years after our business relationship ends in order that we can comply with our obligations under applicable legislation such as anti-money laundering and anti-fraud regulations. If any changes to applicable legislation require us to retain your data for a longer period of time, we shall retain it for that period. We will not retain your data for longer than is necessary.

Your rights regarding your personal data?
You have certain rights regarding the personal data which we process: 


How is your information protected?
We implement security policies and technical measures in order to secure your personal data and take steps to protect it from unauthorised access, use or disclosure.

While we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

C
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your personal information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Malta is the Office of the Information and Data Protection Commissioner. Their contact details are as follows:

IDPC,
Floor 2, Airways House, Triq il-Kbira, Tas-Sliema, SLM1549, Malta.
(+356) 23287100 / info@idpc.org.mt

Other websites
Our website may contain links to other websites. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

Changes to our Privacy Policy
We keep our Privacy Policy under review and we regularly update it to keep up with business demands and privacy regulation. We will inform you about any such changes. This Privacy Policy was last updated on 27th October 2021.

How to contact us
If you have any questions about our Privacy Policy or the personal information which we hold about you or, please send an email to our Data Protection Officer at DPO@transactpaymentsltd.com.

TMPL Privacy Policy Version 1.0, last updated 28.10.2021