Littlepay Privacy Policy

Last updated: January 11, 2024

Privacy Policy

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 policy will inform you about how we treat your personal data when you use our platforms and services (together “Services”) and when you use our website.

This privacy policy 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 is identified in the section “Country Specific Notices” and 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 the processor of personal information collected and processed for the Services, unless stated otherwise.

What Personal Data Do We Collect?

Personal data, or personal information, means any information about an individual from which that person can be identified.

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 personally identifiable information while you use our website. This includes 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.

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.
Information provided by third parties. We may collect personal data about you from third parties, as set out below:
- Personal data collected while processing your payment. If you are a card-holder making a payment to a merchant using our Services to process your payment, we may, directly or through a merchant using our payment processing service, collect, store and process financial and transaction related personal data about you and your transaction. This may include your billing address, delivery address, date of birth, purchase amount, date of purchase, payment method, credit or debit card number, bank account information and additional necessary information required to process your transaction. Merchants are responsible for providing appropriate privacy information to you about our processing of your data.
- 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.
- 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 marketing our Services, we may collect identity and contact data from publicly available sources.

Merchant Information. If you are a Merchant, we will process your email address for our online Control Portal (a PCI-compliant and responsive web portal for Merchants to view individual passenger transactions).

Traveller information. If you are a Traveller, we will process your payment card details for our online Traveller Portal (a PCI-compliant and responsive web portal for Travellers to view individual passenger transactions).

How Do We Use Your Personal Data?

We process your personal data:

To perform 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 mitigating 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 improve and analyse our products, website, systems and tools.
Where we have your consent to do so for any other reason.

The following examples demonstrate how we may process your personal data:

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.
Process a payment, communicate with third-parties regarding a payment, and provide related customer service.
Monitor illegitimate activities and prevent information security risks related to our website and Services.
Evaluate your application to use our Services and verify your identity for compliance purposes.
Respond to inquiries, send service notices and provide customer support.
For audits, regulatory purposes, and compliance with industry standards.
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.
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.

Purposes For Which We Will Use Your Personal Data

The table below describes the purposes for which we plan to your use your personal data and law lawful basis of our processing activities:

Purpose	Type of Data	Legal basis for processing including basis of legitimate interest
To facilitate and enable our relationship with you as a prospective, new or existing merchant	Identity and contact details	Performance of a contract Necessary to comply with a legal obligation Necessary for our legitimate interests (for running our business and to prevent fraud)
To process and execute your transaction, and other payments related activities, including: Manage payments, fees and charges Collect and recover funds for our business purposes	Identity, contact details and transaction details	Performance of a contract Necessary to comply with a legal obligation Necessary for our legitimate interests (for running our business and to prevent fraud) Processing of your personal data for this purpose may include automated decision-making
To manage our relationship with you as a user of our website or Services, which will include: Notifying you about changes to our Service, terms or privacy policy Provide Services to you	Identity and contact details	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical, device and usage details	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity, contact details and technical details	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation

Notice To Our Merchants

We may collect, use and disclose certain personal data about your customers when acting as your service provider. You are responsible for making sure that your customer’s privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. You must comply with the personal data protection laws of your country of origin and of those countries in which you offer products or services and, in particular when processing and sending personal data to us in the context of using the Services and submitting transactions.

Who Do We Share Your Personal Data With?

We share your personal data with trusted third parties for the purpose of providing our Services 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 will 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 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. We also use and disclose your personal data as we believe necessary (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions, or our PSP Service Agreement and other agreements, as applicable; (iii) to protect our rights, privacy safety or property, and/or that of our affiliates, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

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 EU data protection standards 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)

The personal data we collect from you is stored and processed at data centres in the EEA.

Littlepay will take all reasonable legal, technical, and organisational measures to ensure that if your personal data is transferred outside of the EEA, it will be treated securely and with an adequate level of protection compared to the level of protection offered within the EEA.

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

We have taken specific steps, in accordance with European data protection law, to protect your personal data. In particular, we will strive to restrict the transfer of your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Transfers of personal data outside of the European will take place only where the organisation receiving the personal data has provided us with adequate safeguards, and subject to a written agreement, in line with the requirements of European data protection law applicable to processors and data transfers.

If you transact with parties outside the EEA, for example by: (i) transacting with a merchant based outside the EEA; (ii) using a payment method based or commonly used outside of the EEA; or (iii) using a non-EEA currency; we may be required to transfer your personal data to those parties in order to provide the Services you requested.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed, altered or disclosed in an unauthorised manner.

We are PCI DSS (Payment Card Industry Data Security Standard) Level 1 compliant, which is the highest standard set by the payment card industry to ensure that payment card data is processed, stored or transmitted in a secure environment.

In addition, we limit access to your personal information to those employees and third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

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.

In some circumstances you can ask us to delete your data: see below for further information about your rights.

In some circumstances we may anonymise your personal data for statistical purposes in which case we may use this information indefinitely without further notice to you.

Links to other websites

Our website may contain links to other third-party websites. This privacy policy does not govern these other websites and we are not responsible for the privacy practices or the content of any website(s) owned and operated by any such third parties. We encourage you to read the privacy statements for each website you visit.

Your Rights

Under certain circumstances, you have rights under data protection laws in respect of your personal data, including the right to:

access your personal data (known as a “data subject access request”);
request the correction of your personal data;
request the erasure of your data;
request the restriction of processing of your personal data;
withdraw consent to the processing of your personal data; and
request the transfer of your personal data to you or a third party.

You may also, in certain circumstances, have the right to object to your data being processed, including where we are processing your data for direct marketing purposes.

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 policy, 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.

California Privacy Policy

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.

How We Collect, Use, and Disclose your Personal Information. The “What Personal Data Do We Collect?” section above describes the categories of personal information we may have collected over the last 12 months. We collect this information for the purposes described in the “Purpose for Which We Will Use Your Personal Data” section, and we share this information as described in the “Who Do We Share Your Personal Data With?” section.

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 confirmation 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 the United Kingdom and European Economic Area (“EEA”)

The following supplemental information is provided for individuals whose personal information is collected or held by Littlepay Limited or any of its affiliated companies in the UK or EEA:

When processing personal data of data subjects who are in the United Kingdom or European Economic Area or in connection with Littlepay Limited’s Services, Littlepay Limited will act either as data controller or data processor. When Littlepay Limited determines the purpose and the manner of processing of your personal data, Littlepay Limited is deemed to be a data controller. We apply a similar approach to protecting your data whether acting as a data processor or a data controller.
Littlepay Limited is registered in the United Kingdom under Company Number 09709888, with its registered address at Ridge Court, The Ridge, Epsom, KT18 7EP, United Kingdom. Littlepay Limited is registered with the UK Information Commissioner’s Office (ICO)under number ZA451546.
If you are a resident of UK and have a complaint regarding our processing of personal data, you are entitled to make a complaint at any time to the ICO, however, where possible, we would appreciate the opportunity to deal with your concerns directly, so please contact us in the first instance.

If you are a resident of 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.

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 policy.

Changes to this Privacy Policy

We will regularly review and update this policy. 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 policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.