Privacy Notice

Important Information and Who We Are 

The Littlepay Group which includes Littlepay Limited and its affiliates (“Littlepay”, “we” or “us”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we treat your personal data when you use our platforms and services (together, the “Services”) and when you use our website. 

This privacy notice is issued on behalf of the Littlepay Group so when we use the terms “Littlepay”, “we”, “us” or “our”, we are referring to the relevant company in the Littlepay Group responsible for processing your data, which will depend on your location and the services you receive from Littlepay.

Littlepay is committed to adequately protecting your personal data regardless of where it is processed and regardless of your location. 

Littlepay is a data controller in respect of your personal data for the purposes of applicable data protection laws, including the EU’s General Data Protection Regulation (“EU GDPR”) and national implementing legislation, the UK GDPR (the EU GDPR as transposed into the laws of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018). We are responsible for ensuring that we use your personal data in compliance with data protection law.

Littlepay as a Data Processor

Littlepay may process personal data relating to end users, travellers and cardholders on behalf of our merchants, partners, and other customers (the “Customers”) when providing payment processing services. When we are processing personal data for this purpose, we do so as a “data processor” under the EU GDPR and / or UK GDPR (as applicable). We are committed to ensuring that any personal data processed by us as a data processor is processed in accordance with applicable data protection laws.
For further information on how your personal data is handled in relation to these services, please refer to the privacy information provided by the relevant Customer.
What Personal Data Do We Collect?
Personal data, or personal information, means any information about an individual from which that person can be identified, either directly or indirectly.

Our Website

When you use our website, we may collect, use, store and transfer the following data:

• Information you give us while using our website. We may ask you to provide us with personal data in connection with your use of our website. This may include your full name, e-mail address, phone number and your company details.
• Cookies and other automated technologies. We may use cookies and other technologies, to collect information that your browser sends us when you are using our website. This includes your computer’s internet protocol, browser type, browser version, the country from which you visited our website, how you arrived at our website, length of your visit and which pages you viewed. Please refer to our cookie policy for further information about how we use cookies and similar technologies.

Marketing

When marketing our Services, we may collect identity and contact data from publicly available sources.

Our Services

When you use our Services, we may collect, use, store and transfer the following personal data:

Information you give us. We may collect personal data directly from you, as set out below:

• Personal data collected from Sandbox users. We will ask you to provide us with personal data to provide you access to our Sandbox. If you request to use our Sandbox, we will collect, store and process personal data, such as your full name, e-mail address and your website.
• Personal data collected from our merchants. We will ask you to provide us with personal data when you apply to become our merchant. We may require you to provide us with additional personal data as you use our Services. If you are a merchant applying to use our Services, we will collect, store and process personal data relating to you and other individuals associated with you, such as full name, email address, date of birth, home address, proof of address, photocopy of a personal identification card or passport and other information as required to on-board you and meet applicable legal requirements.

When securing our website and Services, we may collect details about your device, your transaction, your computer’s internet protocol and other technical information, through our data security and firewall providers.
When required for compliance with applicable laws, we may verify your information and collect information from publicly available sources, credit reference or fraud prevention agencies or check data against government sanction lists, either directly, or using identity verification providers or due diligence and screening information providers.

How Do We Use Your Personal Data?

Your personal data may be stored and processed by us in the following ways and for the following purposes:

• To manage risk and protect the website, the Services and you from fraud, abuse and other illegitimate activities, by monitoring, detecting and preventing such activities.
• To comply with our obligations and to enforce the terms of our website and Services, including to comply with all applicable laws and regulations.
• To process a payment, communicate with third-parties regarding a payment, and provide related customer service.
• To monitor illegitimate activities and prevent information security risks related to our website and Services.
• To evaluate your application to use our Services and verify your identity for compliance purposes.
• To respond to inquiries, send service notices and provide customer support.
• For audits, regulatory purposes, and compliance with industry standards.
• To notify you about changes to the nature or terms of our Service.
• To administer our website, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To improve our website to ensure that content is presented in the most effective manner.
• To authenticate your access to your account.
• To improve or modify our Services.
• To develop new products.
• To send marketing communications.
• To conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.

Legal Bases For Processing Your Personal Data

The relevant legal bases which apply in respect of our data processing activities are as follows:

• To perform the Services under the contract we are about to enter into or have entered into with you. 
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, such as:
  • to facilitate our relationship with you as a prospective, new or existing merchant;
  • to process and execute your transactions, and other payments related activities, including managing payments, fees and charges and collecting and recovering funds for our business purposes;
  • to manage our relationship with you as a user of our website or Services, which includes notifying you about changes to our Services, terms of services or this privacy notice;
  • to improve our website, products and services, marketing, customer relationships and experiences;
  • to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); and
  • to mitigate financial loss or other harm to our merchants, you and us. 
• Where we need to comply with legal or regulatory obligations, such as detecting and preventing fraud. 
• Where we need to establish, exercise or defend our legal rights or for the purpose of legal proceedings.
• Where we have obtained your consent to do so.

Who Do We Share Your Personal Data With? 

We may share your personal data with trusted third parties for the purpose of providing our Services to you and promoting our business, as follows: 

• Affiliates. Our affiliates within the Littlepay Group to provide you with our Services.
• Business partners, payment industry suppliers and participants to your transactions. We may share your personal data with our merchants and their service providers, card schemes, payment method providers and third party acquirers, as necessary to process payments or provide our Services. The information shared includes:
  • personal data necessary to facilitate the transaction and activities related to your transaction;
  • personal data to help our partners resolve disputes and detect and prevent fraud; and
  • personal data and performance analytics to help our merchants better understand the uses of their platform and to help our merchants enhance their customers’ experiences.
• Third party service providers.
  • We may use third party service providers acting on our behalf. These service providers help us with data and cloud services, website hosting, data analysis, application services, advertising networks, information technology and related infrastructure, customer service, communications and auditing.

Other third parties. We may share your personal data with third parties in the event that we sell, buy or merge any business or assets, including to the prospective seller or buyer of such business or assets. 

Safety, Legal Purposes and Law Enforcement. We may share your personal data with third parties including the police and law enforcement to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of Littlepay, our users, customers, employees or the public or as otherwise required by law. 

All our third-party service providers and other entities in the group are required to process the personal data in accordance with applicable data protection regulations and to take appropriate security measures to protect your personal information in line with applicable data protection regulations and our policies.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transfer of personal data outside the European Economic Area (“EEA”) or United Kingdom (“UK”)

We may share your personal data with members of the Littlepay Group or other third parties who are based outside of the EEA or the UK. We may share your personal data with partners, suppliers or sub-processors based in countries outside of the EEA or the UK. 

We will ensure that any transfer of personal data outside of the EEA or UK (as applicable) is subject to adequate safeguards, or is otherwise permitted under applicable data protection law. For example, the country or jurisdiction to which the personal data is transferred may be approved by the data protection authority of that country or jurisdiction as offering an adequate level of protection for your personal data, or the recipient may have agreed to model contractual clauses approved by the data protection authority of the country or jurisdiction that oblige them to protect the personal data.

Retention of your Information

We retain your personal data in an identifiable format for the least amount of time necessary to fulfil our legal or regulatory obligations and for our business purposes. We may retain your personal data for a longer period when there is a specific legal requirement to do so, for example in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, tax, regulatory or reporting requirements. To determine the appropriate retention period for personal data, we 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. 

Your Rights 

Under certain circumstances, you have rights under data protection laws (including the EU GDPR and UK GDPR, as applicable) in respect of your personal data. Depending on your location, these rights may include the right to:

• obtain information regarding the processing of your personal data and to access your personal data (known as a “data subject access request”); 
• in some circumstances, receive some personal data in a structured, commonly used and machine-readable format and the right to request that Littlepay transmits that data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to Littlepay;
• request the correction of your personal data if it is inaccurate or incomplete;
• request the erasure of your data in certain circumstances. Please note that there may be circumstances where you ask Littlepay to erase your personal data but Littlepay is legally entitled to retain it;
• request that Littlepay restricts, or the right to object to the processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask Littlepay to restrict, its processing of your personal data but Littlepay is legally entitled to continue processing your personal data or to refuse that request;
• withdraw your consent to the processing of your personal data. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so; and
• lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by Littlepay.

If you would no longer like to receive marketing communications, please use the details within the communication itself to unsubscribe or contact us at legal@littlepay.com with the subject line “Unsubscribe.”

If you wish to exercise any of the rights set out above or have any queries on any aspect of our privacy notice, please contact our legal department by email at legal@littlepay.com or by post to: Littlepay Limited, Ridge Court, The Ridge, Epsom, KT18 7EP, UK.

You can find out more information about your rights by contacting a relevant supervisory authority, such as the UK’s Information Commissioner’s Office, or by searching its website (https://ico.org.uk/).

If you are a resident in the EEA and have a complaint regarding our processing of personal data you can contact Littlepay or its representative appointed  the European Union, VeraSafe using this form: https://verasafe.com/public-resources/contactdata-protection-representative or via telephone at: +420 228 881 031. Alternatively, VeraSafe can be contacted at: VeraSafe Ireland Ltd. Unit 3D North Point House North Point Business Park New Mallow Road Cork T23AT2P Ireland.

California Privacy Notice

This section provides additional details about the personal information (as that term is defined in the California Consumer Privacy Act (“CCPA”)) we collect about California consumers, as well as requests California consumers can make regarding their personal information.

Requests About Your Personal Information. California consumers can make the following requests with respect to their personal information:

• Access the personal information we hold about you. You may request a copy of the personal information that we have collected about you. 
• Deletion of your personal information. Subject to certain limitations under applicable law, you may request that we delete the personal information we have collected from you. 
• Non-discrimination. You have the right not to be discriminated against for exercising any of your rights under CCPA. 

Littlepay does not sell personal information about consumers within the meaning of the CCPA. However, the collection of data through third party cookies for our targeted advertising purposes may be considered a “sale” under the CCPA. While we do not sell personal information, we do use third party cookies for targeted advertising purposes. If you do not want you information shared with such parties, you may manage your cookie preferences under the cookie policy.

Littlepay does not share (and has not shared in the preceding twelve months) your personal information with third parties for their own direct marketing purposes. If you reside in California, you have the right to ask us (under the California “Shine the Light” law), once a year, if we have shared information with any third parties for their direct marketing purposes. 

Contact. To submit a request to exercise any of your rights above, you can contact our Legal Department using the contact details provided above. Please note that we will need to request certain information to verify your identity before responding to your request.

Country-Specific Notices

Notice relating to our operations in Australia 

The following supplemental information is provided for individuals whose personal information is collected or held by Littlepay Limited, Littlepay Pty Ltd, or any of their affiliated companies, at a time when the collecting or holding entity has an ‘Australian link’ within the meaning of the Australian Privacy Act 1988:

• You may make a complaint to us about a breach of the Australian Privacy Principals by using the contact details of our DPO, as set out above. We will investigate your complaint and endeavour to resolve any issue to your satisfaction. If we do not adequately answer your concerns, you will have the right to make a complaint in writing to the Office of the Australian Information Commissioner. 
• It is likely that personal information about you will be collected and held in countries within the EEA or the United Kingdom. It may also be disclosed to persons in other countries in the circumstances described in this privacy notice. 

Changes to this Privacy Notice

We will regularly review and update this privacy notice. Any changes we make will be posted on this page and, where appropriate, notified to you by email. Please check this page regularly to see any updates or changes to our privacy notice.

The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.