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DATA PROCESSING AGREEMENT

DATA PROCESSING AGREEMENT

1. GENERAL CONDITIONS

This Data Processing Agreement (“DPA”) shall regulate the Processing of Personal Data of Data Subjects subject to EU Data Protection Laws for the Purposes specified in clause 3 herein by the Parties in the context of the Services. Annex 1 and Annex 2 form an integral part of this DPA.

2. DEFINITIONS

Capitalised terms not otherwise defined herein shall have the meaning given to them in the Agreement (“Agreement” as defined in the Terms and Conditions). In this DPA, the following terms shall have the following meanings:

  • 2.1. “PARTNER” means a legal or a natural person, with whom ECOMMPAY concludes the Agreement;
  • 2.2. "Controller" means a legal person which, alone or jointly with others, determines the Purposes and means of the Processing;
  • 2.3. “Data Subject” means an employee, beneficial owner/principal, shareholder, representative, or director of the Merchant or the Partner, or other natural person, whose Personal Data are Processed in the context of the Agreement;
  • 2.4. "EEA" means the European Economic Area;
  • 2.5. “EU Data Protection Laws” means the EU General Data Protection Regulation 2016/679 (GDPR) and the e-Privacy Directive 2002/58/EC (as amended by Directive 2009/136/EC, and as amended and replaced from time to time) and their national implementing legislations; the Data Protection Bill of the United Kingdom (as amended and replaced from time to time); and the Data Protection Laws of the EEA countries (as amended and replaced from time to time);
  • 2.6. “Personal Data” means any information relating to an identified or identifiable Data Subject, who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that Data Subject; the reference to ‘data’ shall be a reference to Personal Data;
  • 2.7. “Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed;
  • 2.8. “Processing” means any operation which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  • 2.9. “Processor” means a legal or a natural person which Processes Personal Data on behalf of the Controller;
  • 2.10. “Purposes” means Personal Data Processing purposes as specified in clause 3 of this DPA;
  • 2.11. “Services” means Services provided by the PARTNER to ECOMMPAY in accordance with the Agreement;
  • 2.12. “Supervisory Authority” means an independent public authority established by a Member State pursuant to Article 51 of the GDPR.

3. ROLES OF THE PARTIES

For the purpose of the DPA, the Parties acknowledge and confirm that:

  • 3.1. Each Party shall be the Controller in relation to Personal Data where each Party individually determines the purposes and the means of the Processing necessary under the Agreement.
  • 3.2. ECOMMPAY shall be the Controller in relation to Personal Data where ECOMMPAY determines the purposes and the means of the Processing (specified in detail in Annex 1), including, but not limited to, the following Purposes:
  • 3.2.1. complying with any rule, regulation or law to which ECOMMPAY is subject;
  • 3.2.2. entering into the Agreement with the PARTNER;
  • 3.2.3. entering into an agreement with the Approved Merchant;
  • 3.2.4. managing the Personal Data received from the PARTNER;
  • 3.2.5. conducting risk management activities including fraud monitoring, prevention and detection;
  • 3.2.6. complying with the Know Your Customer requirements;
  • 3.2.7. complying with requirements for the prevention of money laundering and terrorism financing;
  • 3.2.8. assessing and/or mitigating financial, information security, and other risks arising in connection with the Agreement.
  • 3.3. PARTNER shall be the Controller in relation to Personal Data where the PARTNER determines the purposes and the means of the Processing (specified in detail in Annex 1), including, but not limited to, the following Purposes:
  • 3.3.1. complying with any rule, regulation or law to which the PARTNER is subject;
  • 3.3.2. entering into the Agreement with the ECOMMPAY;
  • 3.3.3. collecting, managing and transferring to ECOMMPAY the Personal Data provided by the Merchant;

4. OBLIGATIONS OF THE CONTROLLER

Each Party acting in a capacity of a Controller represents and warrants that it shall:

  • 4.1. Comply with EU Data Protection Laws in respect of Processing of Personal Data, as well as cooperate with the other Party to fulfil its respective Personal Data protection compliance obligations in accordance with EU Data Protection Laws.
  • 4.2. Rely on a valid legal ground under EU Data Protection Laws for Processing Personal Data for each Purpose and, where relevant, obtain the consent of the Data Subjects, prior to processing and transferring the Personal Data to the other Party.
  • 4.3. Respond to Data Subject requests to exercise their rights of (i) access, (ii) rectification, (iii) erasure, (iv) data portability, (v) restriction of Processing, and (vi) objection to the Processing in accordance with EU Data Protection Laws, and, where necessary, assist the other Party in fulfilling its obligation to respond to Data Subjects’ requests, as well as notify the other Party about such requests, provided that such requests concern the Processing conducted by the other Party.
  • 4.4. Promptly inform the other Party if, in the Controller’s opinion, the other Party infringes the EU Data Protection Law in respect to the Processing of Personal Data in the context of the Services.
  • 4.5. Notify the other Party when local laws prevent the Controller from fulfilling its obligations under this Agreement and have a substantial adverse effect on the guarantees provided by this Agreement except where such disclosure is prohibited by the applicable law.
  • 4.6. Ensure that any Processors engaged by the Controller in order to Process Personal Data in the context of the Services shall comply with the EU Data Protection Laws and shall abide with the obligations set out in this Agreement.

5. PROCESSING

  • 5.1. The Parties hereby generally authorise each other to engage internal and external Processors in order to Process Personal Data in the context of the Services and to continue using the internal and external Processors already engaged in relation to the Services.
  • 5.2. Each Party shall conclude a written agreement with its internal and external Processors, wherein the Processors guarantee to comply with the requirements of EU Data Protection Laws, and with the obligations imposed by this Agreement.

6. DATA TRANSFERS OUTSIDE THE EEA

  • 6.1. In the event the PARTNER is located outside the EEA, the Parties shall conclude the Standard Contractual Clauses set out in Annex 2. ECOMMPAY shall be considered as importer and the PARTNER shall be considered as exporter for the purposes of the Standard Contractual Clauses.
  • 6.2. If the Personal Data is in in any instance transferred from the EEA, the Parties hereby authorise each other to transfer the Personal Data Processed in connection with the Technical Integration to their internal and external Processors located in the territories outside of the EEA, provided that appropriate safeguards for the Personal Data transfer outside the EEA are in place.

7. SECURITY AND CONFIDENTIALITY OF THE PROCESSING

  • 7.1. The Parties shall implement appropriate technical and organisational measures in order to ensure the appropriate level of security. In this regard the Parties shall take into account the state of the art, the costs of implementation and the nature, scope, context and Purposes of Processing of Personal Data as well as the risk of varying likelihood and severity for the rights and freedoms of Data Subjects and the risks that are presented by the Processing of Personal Data, in particular from Personal Data Breach.
  • 7.2. The Parties shall ensure that any person acting under their authority and having access to Personal Data is subject to a duly enforceable contractual or statutory confidentiality obligation.
  • 7.3. The Parties shall ensure that any person acting under their authority and having access to Personal Data is appropriately trained in line with their responsibilities under the EU Data Protection Laws.

8. PERSONAL DATA BREACH

  • 8.1. The Parties shall notify a Personal Data Breach that relates to Personal Data Processed in the context of the Services to the other Party, without undue delay, and no later than 48 hours after having become aware of a Personal Data Breach. The notifying Party shall provide sufficient information to allow the other Party to meet its obligations under the EU Personal Data Protection Laws.
  • 8.2. The Parties shall cooperate to reach an agreement on notifying a Personal Data Breach to the Supervisory Authority and to the Data Subjects and assist in the investigation, mitigation and remediation of each Personal Data Breach.
  • 8.3. The Parties shall thoroughly document all Personal Data Breaches, including all the relevant facts relating to the Personal Data Breach, its effects and the remedial action taken.

9. AUDIT RIGHTS

  • 9.1. Upon prior written request by ECOMMPAY, the PARTNER agrees to cooperate and within reasonable time provide ECOMMPAY with information necessary to demonstrate compliance with the EU Data Protection Laws and this DPA.
  • 9.2. If the information provided is not sufficient to confirm compliance with EU Data Protection Laws or reveals material issues, subject to the strictest confidentiality obligations, the PARTNER allows ECOMMPAY to request an audit of the PARTNER’s data protection compliance program by external independent auditors, which are jointly selected by the Parties. The Parties shall mutually agree upon the scope, timing, and duration of the audit. The PARTNER shall make available to ECOMMPAY the result of the audit.

ANNEX 1: DESCRIPTION OF THE PROCESSING ACTIVITIES

1. Purposes of the Processing

ECOMMPAY Processes Personal Data transferred by PARTNER within the course of receiving the PARTNER’s Services, pursuant to the Agreement and the DPA as described therein, which may include, without limitation:

  • complying with any rule, regulation or law to which ECOMMPAY is subject;
  • entering into the Agreement with the PARTNER;
  • entering into an agreement with the Approved Merchant;
  • managing the Personal Data received from the PARTNER;
  • conducting risk management activities including fraud monitoring, prevention and detection;
  • complying with the Know Your Customer requirements;
  • complying with requirements for the prevention of money laundering and terrorism financing; assessing and/or mitigating financial, information security, and other risks arising in connection with the Agreement. PARTNER Processes Personal Data transferred to ECOMMPAY within the course of providing Services, pursuant to the Agreement and the DPA, as described therein, which may include, without limitation:
  • complying with any rule, regulation or law to which the PARTNER is subject;
  • entering into the Agreement with the ECOMMPAY;
  • collecting, managing and transferring to ECOMMPAY the Personal Data provided by the Merchant;

*For the purposes of Annex 1, “Merchant” may as well include affiliate companies of the Merchant.

2. Categories of Data Subjects

The Parties may Process Personal Data relating to the following categories of Data Subjects, as applicable:

  • The Merchant’s beneficial owners/principals, shareholders, directors;
  • Family members of the Merchant’s beneficial owners/principals;
  • The Merchant’s employees;
  • The other Party’s beneficial owners/principals, shareholders, directors and employees.

3. Types of Personal Data

The Parties may Process Personal Data, including but not limited to, the following categories of Personal Data:

  • First and last name;
  • Date of birth;
  • Home, work or other physical address;
  • Postal code/zip;
  • Country;
  • Telephone/mobile phone number;
  • Email address;
  • IP address;
  • Company name;
  • Company registration number;
  • Current Position;
  • Previous places of employment;
  • Education;
  • Passport or ID data;
  • Credit/financial institution account number;
  • Information regarding the beneficial ownership in other companies.

4. Duration of the Processing

Personal Data may be Processed and stored for the period necessary to fulfil the agreed Purposes of Processing pursuant the Agreement and the DPA, or as otherwise authorised by the applicable law.

ANNEXE 2

STANDARD CONTRACTUAL CLAUSES FOR THE TRANSFER OF PERSONAL DATA FROM THE COMMUNITY TO THIRD COUNTRIES (CONTROLLER TO CONTROLLER TRANSFERS) (SET II)*

DATA TRANSFER AGREEMENT

*According to 2004/915/EC: Commission Decision of 27 December 2004 amending Decision 2001/497/EC as regards the introduction of an alternative set of standard contractual clauses for the transfer of personal data to third countries, these Standard Contractual Clauses are required to be entered into in their original wording, without any amendments made.

Definitions

For the purposes of the clauses:

  • (a) “personal data”, “special categories of data/sensitive data”, “process/processing”, “controller”, “processor”, “data subject” and “supervisory authority/authority” shall have the same meaning as in Directive 95/46/EC of 24 October 1995 (whereby “the authority” shall mean the competent data protection authority in the territory in which the data exporter is established);
  • (b) “the data exporter” shall mean the controller who transfers the personal data;
  • (c) “the data importer” shall mean the controller who agrees to receive from the data exporter personal data for further processing in accordance with the terms of these clauses and who is not subject to a third country’s system ensuring adequate protection;
  • (d) “clauses” shall mean these contractual clauses, which are a free-standing document that does not incorporate commercial business terms established by the parties under separate commercial arrangements. The details of the transfer (as well as the personal data covered) are specified in Annex B, which forms an integral part of the clauses.

I. Obligations of the data exporter

The data exporter warrants and undertakes that:

  • (a) The personal data have been collected, processed and transferred in accordance with the laws applicable to the data exporter;
  • (b) It has used reasonable efforts to determine that the data importer is able to satisfy its legal obligations under these clauses;
  • (c) It will provide the data importer, when so requested, with copies of relevant data protection laws or references to them (where relevant, and not including legal advice) of the country in which the data exporter is established;
  • (d) It will respond to enquiries from data subjects and the authority concerning processing of the personal data by the data importer, unless the parties have agreed that the data importer will so respond, in which case the data exporter will still respond to the extent reasonably possible and with the information reasonably available to it if the data importer is unwilling or unable to respond. Responses will be made within a reasonable time;
  • (e) It will make available, upon request, a copy of the clauses to data subjects who are third party beneficiaries under clause III, unless the clauses contain confidential information, in which case it may remove such information. Where information is removed, the data exporter shall inform data subjects in writing of the reason for removal and of their right to draw the removal to the attention of the authority. However, the data exporter shall abide by a decision of the authority regarding access to the full text of the clauses by data subjects, as long as data subjects have agreed to respect the confidentiality of the confidential information removed. The data exporter shall also provide a copy of the clauses to the authority where required.

II. Obligations of the data importer

The data importer warrants and undertakes that:

  • (a) It will have in place appropriate technical and organisational measures to protect the personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, and which provide a level of security appropriate to the risk represented by the processing and the nature of the data to be protected;
  • (b) It will have in place procedures so that any third party it authorises to have access to the personal data, including processors, will respect and maintain the confidentiality and security of the personal data. Any person acting under the authority of the data importer, including a data processor, shall be obligated to process the personal data only on instructions from the data importer. This provision does not apply to persons authorised or required by law or regulation to have access to the personal data;
  • (c) It has no reason to believe, at the time of entering into these clauses, in the existence of any local laws that would have a substantial adverse effect on the guarantees provided for under these clauses, and it will inform the data exporter (which will pass such notification on to the authority where required) if it becomes aware of any such laws;
  • (d) It will process the personal data for purposes described in Annex B, and has the legal authority to give the warranties and fulfil the undertakings set out in these clauses;
  • (e) It will identify to the data exporter a contact point within its organisation authorised to respond to enquiries concerning processing of the personal data, and will cooperate in good faith with the data exporter, the data subject and the authority concerning all such enquiries within a reasonable time. In case of legal dissolution of the data exporter, or if the parties have so agreed, the data importer will assume responsibility for compliance with the provisions of clause I(e);
  • (f) At the request of the data exporter, it will provide the data exporter with evidence of financial resources sufficient to fulfil its responsibilities under clause III (which may include insurance coverage);
  • (g) Upon reasonable request of the data exporter, it will submit its data processing facilities, data files and documentation needed for processing to reviewing, auditing and/or certifying by the data exporter (or any independent or impartial inspection PARTNERs or auditors, selected by the data exporter and not reasonably objected to by the data importer) to ascertain compliance with the warranties and undertakings in these clauses, with reasonable notice and during regular business hours. The request will be subject to any necessary consent or approval from a regulatory or supervisory authority within the country of the data importer, which consent or approval the data importer will attempt to obtain in a timely fashion;
  • (h) It will process the personal data, at its option, in accordance with:
  • i. the data protection laws of the country in which the data exporter is established, or
  • ii. the relevant provisions (1) of any Commission decision pursuant to Article 25(6) of Directive 95/46/EC, where the data importer complies with the relevant provisions of such an authorisation or decision and is based in a country to which such an authorisation or decision pertains, but is not covered by such authorisation or decision for the purposes of the transfer(s) of the personal data (2), or
  • iii. the data processing principles set forth in Annex A.

Data importer to indicate which option it selects: iii

Initials of data importer: ECOMMPAY LIMITED

  • (i) It will not disclose or transfer the personal data to a third-party data controller located outside the European Economic Area (EEA) unless it notifies the data exporter about the transfer and
  • i. the third-party data controller processes the personal data in accordance with a Commission decision finding that a third country provides adequate protection, or
  • ii. the third-party data controller becomes a signatory to these clauses or another data transfer agreement approved by a competent authority in the EU, or
  • iii. data subjects have been given the opportunity to object, after having been informed of the purposes of the transfer, the categories of recipients and the fact that the countries to which data is exported may have different data protection standards, or
  • iv. with regard to onward transfers of sensitive data, data subjects have given their unambiguous consent to the onward transfer.

III. Liability and third-party rights

  • (a) Each party shall be liable to the other parties for damages it causes by any breach of these clauses. Liability as between the parties is limited to actual damage suffered. Punitive damages (i.e. damages intended to punish a party for its outrageous conduct) are specifically excluded. Each party shall be liable to data subjects for damages it causes by any breach of third party rights under these clauses. This does not affect the liability of the data exporter under its data protection law.
  • (b) The parties agree that a data subject shall have the right to enforce as a third party beneficiary this clause and clauses I(b), I(d), I(e), II(a), II(c), II(d), II(e), II(h), II(i), III(a), V, VI(d) and VII against the data importer or the data exporter, for their respective breach of their contractual obligations, with regard to his personal data, and accept jurisdiction for this purpose in the data exporter’s country of establishment. In cases involving allegations of breach by the data importer, the data subject must first request the data exporter to take appropriate action to enforce his rights against the data importer; if the data exporter does not take such action within a reasonable period (which under normal circumstances would be one month), the data subject may then enforce his rights against the data importer directly. A data subject is entitled to proceed directly against a data exporter that has failed to use reasonable efforts to determine that the data importer is able to satisfy its legal obligations under these clauses (the data exporter shall have the burden to prove that it took reasonable efforts).

IV. Law applicable to the clauses

These clauses shall be governed by the law of the country in which the data exporter is established, with the exception of the laws and regulations relating to processing of the personal data by the data importer under clause II(h), which shall apply only if so selected by the data importer under that clause.

V. Resolution of disputes with data subjects or the authority

  • (a) In the event of a dispute or claim brought by a data subject or the authority concerning the processing of the personal data against either or both of the parties, the parties will inform each other about any such disputes or claims, and will cooperate with a view to settling them amicably in a timely fashion.
  • (b) The parties agree to respond to any generally available non-binding mediation procedure initiated by a data subject or by the authority. If they do participate in the proceedings, the parties may elect to do so remotely (such as by telephone or other electronic means). The parties also agree to consider participating in any other arbitration, mediation or other dispute resolution proceedings developed for data protection disputes.
  • (c) Each party shall abide by a decision of a competent court of the data exporter’s country of establishment or of the authority which is final and against which no further appeal is possible.

VI. Termination

  • (a) In the event that the data importer is in breach of its obligations under these clauses, then the data exporter may temporarily suspend the transfer of personal data to the data importer until the breach is repaired or the contract is terminated.
  • (b) In the event that:
  • i. the transfer of personal data to the data importer has been temporarily suspended by the data exporter for longer than one month pursuant to paragraph (a);
  • ii. compliance by the data importer with these clauses would put it in breach of its legal or regulatory obligations in the country of import;
  • iii. the data importer is in substantial or persistent breach of any warranties or undertakings given by it under these clauses;
  • iv. a final decision against which no further appeal is possible of a competent court of the data exporter’s country of establishment or of the authority rules that there has been a breach of the clauses by the data importer or the data exporter; or
  • v. a petition is presented for the administration or winding up of the data importer, whether in its personal or business capacity, which petition is not dismissed within the applicable period for such dismissal under applicable law; a winding up order is made; a receiver is appointed over any of its assets; a trustee in bankruptcy is appointed, if the data importer is an individual; a company voluntary arrangement is commenced by it; or any equivalent event in any jurisdiction occurs then the data exporter, without prejudice to any other rights which it may have against the data importer, shall be entitled to terminate these clauses, in which case the authority shall be informed where required. In cases covered by (i), (ii), or (iv) above the data importer may also terminate these clauses.

  • (c) Either party may terminate these clauses if (i) any Commission positive adequacy decision under Article 25(6) of Directive 95/46/EC (or any superseding text) is issued in relation to the country (or a sector thereof) to which the data is transferred and processed by the data importer, or (ii) Directive 95/46/EC (or any superseding text) becomes directly applicable in such country.

  • (d) The parties agree that the termination of these clauses at any time, in any circumstances and for whatever reason (except for termination under clause VI(c)) does not exempt them from the obligations and/or conditions under the clauses as regards the processing of the personal data transferred.

VII. Variation of these clauses

The parties may not modify these clauses except to update any information in Annex B, in which case they will inform the authority where required. This does not preclude the parties from adding additional commercial clauses where required.

VIII. Description of the Transfer

The details of the transfer and of the personal data are specified in Annex B. The parties agree that Annex B may contain confidential business information which they will not disclose to third parties, except as required by law or in response to a competent regulatory or government agency, or as required under clause I(e). The parties may execute additional annexes to cover additional transfers, which will be submitted to the authority where required. Annex B may, in the alternative, be drafted to cover multiple transfers.

ANNEXE A TO THE STANDARD CONTRACTUAL CLAUSES

DATA PROCESSING PRINCIPLES

  • 1. Purpose limitation: Personal data may be processed and subsequently used or further communicated only for purposes described in Annex B or subsequently authorised by the data subject.
  • 2. Data quality and proportionality: Personal data must be accurate and, where necessary, kept up to date. The personal data must be adequate, relevant and not excessive in relation to the purposes for which they are transferred and further processed.
  • 3. Transparency: Data subjects must be provided with information necessary to ensure fair processing (such as information about the purposes of processing and about the transfer) unless such information has already been given by the data exporter.
  • 4. Security and confidentiality: Technical and organisational security measures must be taken by the data controller that are appropriate to the risks, such as against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, presented by the processing. Any person acting under the authority of the data controller, including a processor, must not process the data except on instructions from the data controller.
  • 5. Rights of access, rectification, deletion and objection: As provided in Article 12 of Directive 95/46/EC, data subjects must, whether directly or via a third party, be provided with the personal information about them that an organisation holds, except for requests which are manifestly abusive, based on unreasonable intervals or their number or repetitive or systematic nature, or for which access need not be granted under the law of the country of the data exporter. Provided that the authority has given its prior approval, access need also not be granted when doing so would be likely to seriously harm the interests of the data importer or other organisations dealing with the data importer and such interests are not overridden by the interests for fundamental rights and freedoms of the data subject. The sources of the personal data need not be identified when this is not possible by reasonable efforts, or where the rights of persons other than the individual would be violated. Data subjects must be able to have the personal information about them rectified, amended, or deleted where it is inaccurate or processed against these principles. If there are compelling grounds to doubt the legitimacy of the request, the organisation may require further justifications before proceeding to rectification, amendment or deletion. Notification of any rectification, amendment or deletion to third parties to whom the data have been disclosed need not be made when this involves a disproportionate effort. A data subject must also be able to object to the processing of the personal data relating to him if there are compelling legitimate grounds relating to his particular situation. The burden of proof for any refusal rests on the data importer, and the data subject may always challenge a refusal before the authority.
  • 6. Sensitive data: The data importer shall take such additional measures (e.g. relating to security) as are necessary to protect such sensitive data in accordance with its obligations under clause II.
  • 7. Data used for marketing purposes: Where data are processed for the purposes of direct marketing, effective procedures should exist allowing the data subject at any time to “opt-out” from having his data used for such purposes.
  • 8. Automated decisions: For purposes hereof “automated decision” shall mean a decision by the data exporter or the data importer which produces legal effects concerning a data subject or significantly affects a data subject and which is based solely on automated processing of personal data intended to evaluate certain personal aspects relating to him, such as his performance at work, creditworthiness, reliability, conduct, etc. The data importer shall not make any automated decisions concerning data subjects, except when:
  • (a) (i) such decisions are made by the data importer in entering into or performing a contract with the data subject, and
  • (ii) (the data subject is given an opportunity to discuss the results of a relevant automated decision with a representative of the parties making such decision or otherwise to make representations to that parties. or
  • (b) where otherwise provided by the law of the data exporter.

ANNEXE B TO THE STANDARD CONTRACTUAL CLAUSES

DESCRIPTION OF THE TRANSFER

Data subjects
The personal data transferred concern the categories of data subjects listed in Paragraph 2 of Annex 1 to the DPA.

Purposes of the transfer(s)
The transfer is made for the purposes listed in Paragraph 1 of Annex 1 to the DPA.

Categories of data
The personal data transferred concern the categories of data listed in Paragraph 3 of Annex 1 to the DPA.

Recipients
The personal data transferred may be disclosed only to the recipients with whom Data Processing Agreements have been concluded in line with the requirements of the EU Data Protection Laws and who comply with the requirements of the EU Data Protection Laws.

Sensitive data (if appropriate)
The transfer of sensitive data (special categories of personal data) is not anticipated.

Data protection registration of data exporter (where applicable)
N/A.

Additional useful information (storage limits and other relevant information)
The duration of the processing as described in Paragraph 4 of Annex 1 to the DPA.

Contact points for data protection enquiries
Data importer: dpo@ecommpay.com

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