Privacy
Policy

Overview

Mia Pago takes privacy very seriously. Our pledge to our customers is to collect only that information that is necessary in the provision of our services. We will never sell data to third parties.


This Policy explains everything you need to know about the information we collect about people who use our services, how we use the data and the conditions in which we may disclose it to others, and how we keep it secure. By using our services and consenting to Mia Pago processing your data, you are agreeing to the conditions herein.


If you have any questions or queries about the contents, please email us at privacy@miapago.com, or by writing to The Data Protection Officer, International House, 12 Constance Street, London E16 2DQ.


What type of information do we collect from you?

When you use our Services we may have access to your personal data that you submit to us and personal data for the duration of the transmission. Such Personal Data may include your date of birth, gender, account information, account balance, transactions, information on loans, insurance data and investments data. The manner in which we access, use, process and store your personal data for the provision of the Services is set out below.


We will only collect the data that you need us to collect in order to provide the services that you asked for. We will not collect any data from you that is not needed to fulfill those services.


When you use our website we will not collect any personal data about you, except your IP address, and if you have used the website to contact us, your email address that you will have provided to us.


We only collect your information in line with relevant regulations and laws. This may relate to any of our services that you use, or have used in the past. You’re responsible for making sure the information you give us is accurate and up to date.


How is your information used?

We only use your information to:


  • - Carry out any contractual obligations between us.
  • - Initiate payments/refunds for goods or services.
  • - Provide information to you allowing you to benefit from other services.
  • - Notify you of any changes to our services.

Who has access to your information?

We will not sell or rent your information to any third parties. We will not share your details to anyone for marketing purposes.


Third Party service providers working on our behalf:

We may pass your information to our third party service providers, agents, subcontractors and any other associated organisations for the purpose of completing tasks and providing services to you on our behalf (for example processing a payment or transferring money as you requested). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service that you need, and we have contracts in place that requires each third party provider to keep your information secure and not to use it for their own direct marketing purposes or any other purpose. We will not release your information to third parties beyond those that we have such a contractual relationship with unless we are required to do so by law (e.g. by a court order or for the purposes of prevention of fraud or other crime). In such circumstances, we will take steps with the aim of ensuring that your privacy rights continue to be protected.


Third Party Product Providers we work in association with:

We may work with service providers engaged by you as their agent. When you use their services, the relevant service provider may use your details to carry out their obligations arising from any contracts you have entered into with them. They may be acting as a data controller of your information and therefore we advise you to read their Privacy Policy. If any of these service providers share your information with us, we will use the information in accordance with this Privacy Policy.


The legal basis for processing personal data

In the first instance, the performance of a contract with You. In addition for the purpose of furthering Mia Pago Ltd legitimate interests, including providing better products, services, websites and applications.


Consent

If you provide us with your Credentials we will require your consent to use those Credentials for:


  • - Retrieving your Account Information (including any Personal Data); and to provide such Account Information to the Providers which referred you to us.
  • - Processing payment requests you ask us to.
  • - Retention of your Personal Data

We will not retain your information for any longer than we think is necessary. This may include a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.


When determining the relevant retention periods, we will take into account factors including:


  • - Our contractual obligations and rights in relation to the information involved;
  • - Legal obligation(s) under applicable law to retain data for a certain period of time;
  • - Statute of limitations under applicable law(s);
  • - Our legitimate interests where we have carried out balancing tests (see section on 'How we use your personal information' above);
  • - Disputes (potential);
  • - Guidelines issued by relevant data protection authorities.

Deletion of Personal Data

We will not keep your Personal Data for longer than necessary. We will delete your Personal Data as soon as it is no longer needed to provide the Services to you or upon termination of the Terms of Service.


Should you change your login information at any time, we will no longer be able to access your Personal Data.


Transfer of your personal data outside of the European Economic Area

As part of the services offered to you through this website or other, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”).


By way of example, if you use our services while you are outside the EU, your information may be transferred outside the EEA in order to provide you with those services. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing and/or processing. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken and we remain compliant with the General Data Protection Regulation, with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.


What are your rights as a data subject?

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email privacy@miapago.com. Your rights are as follows:


1. Keeping informed

We are obliged to provide clear and transparent information about our data processing activities.


2. Subject access requests

You have the right to ask us to provide any personal data we have collected about You, to You. If there are exceptional circumstances, or if the requests are frivolous, we can refuse to provide the information.


3. The right to rectification

If you believe we hold inaccurate and / or incomplete personal information about you, you may ask us to correct or complete this data.


4. The right to be forgotten

Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. We will take all reasonable steps to ensure erasure.


5. Restricted processing

You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further (an alternative to the right to be forgotten).


6. Data portability

You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format.


7. The right to object

You have the right to object to our processing of your data where processing is based on legitimate interest.


Security

The internet is not secure. We use industry-standard encryption methods to ensure the security of your Personal Data in accordance with applicable law and regulation. This includes utilising appropriate measures to safeguard data against unauthorised access, disclosure, alteration, or destruction. These measures may include, among others, encryption, physical access security, auditing, and other appropriate technologies.


Cookies

A cookie is a small file of letters and numbers that is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive.


We use cookies to enhance the online experience of our visitors and to better understand how our website is used. Cookies may tell us, for example, whether you have visited our site before or whether you are a new visitor.


When you browse our website, we automatically receive your computer’s internet protocol (IP) address. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.


We use both ‘session cookies’ (which exist only while your browser is open) and ‘permanent cookies’ which survive after your browser is closed. Permanent cookies can be used by the site to recognise your computer or mobile device when you open your browser and browse the Internet again.


Minors

Our Services are not intended for use by anyone younger than 18 years old. Please do not use our Services if you are under 18.


Questions and contact information

If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information about how we process your Personal Data, you can contact us at privacy@miapago.com or by mail at:


Data Protection Officer, Mia Pago Ltd, International House, 12 Constance Street, London E16 2DQ.


Policy Review

We keep this Policy under regular review. This Policy was last updated in November 2018.