PRIVACY POLICY   

Last updated January 27, 2021 

Thank you for choosing PingPong (PingPong Europe S.A. and other companies in the PingPong Group, hereinafter "Company", "we", "us", or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at dpo@pingpongx-eu.com. 

When you visit our website, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy   that you do not agree with, please discontinue use of our Sites and our services. 

This privacy policy applies to all information collected through our website, and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Services").  

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.  

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information.

We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:

Publicly Available Personal Information. We may collect first name, maiden name, last name, ID and identification document information, driver's license number, passport number, current and former address, phone numbers, email addresses, business email, business phone number, business entity filings, corporate affiliations, business associates, and other similar data.   

Personal Information Provided by You. We may collect financial information (credit card number, purchase history, invoices), PingPong account information and other similar data.   

Credentials. We may collect passwords, password hints, and similar security information used for authentication and account access.  

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. 

2. HOW DO WE USE YOUR INFORMATION?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

Below are some definitions that will help you understand the roles and responsibilities of PingPong:

• “data controller” means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be used.
• “data processor”, in relation to personal information, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

If you provide the data and the instructions, then you are the data controller and PingPong is the data processor. 

If we determine the purposes for which we collect and use your personal information, then we are the Controller. 

We use the information we collect or receive:

• To facilitate account creation and logon process.
• To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the " WHAT ARE YOUR PRIVACY RIGHTS " below).     
• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual Obligations.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.                        
• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  
  
• To deliver services to the user. We may use your information to provide you with the requested service.                                                         
  
  
• To respond to user inquiries/offer support to users.  We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.                         

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. 

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose. 
  
  
  
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. 
  
  
  
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. 
  
  
  
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). 
  
  
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.  We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct.    
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. 

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In Short: We only share information with the following third parties.

We may only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

• Cloud Computing Services
  Alibaba Cloud Services
• Our Banking Partners
  
  
• Our Service Providers
  
  
• Our Partner Platforms
  
  
• Our Affiliate Companies
  
  

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.          

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law. 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 10 years past the termination of the user's account. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.   

7. HOW DO WE KEEP YOUR INFORMATION SAFE? 

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.  

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at dpo@pingpongx-eu.com.  

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details  provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.  

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you have questions or comments about your privacy rights, you may email us at dpo@pingpongx-eu.com.  

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account. 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.    

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may: 

    ■ Note your preferences when you register an account with the site.  

    ■ Access your account settings and update preferences.  

    ■ Contact us using the contact information provided.      

10. DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when PingPong believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that PingPong becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information PingPong will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.   

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.  

12. DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EEA?

As an international payments company, we sometimes need to share your personal data with financial institutions and service providers outside the EEA. For example, if you transfer money to an account outside the EEA. We will make sure that we only share your data to be able to provide you with the services you want from us and that the data will only be retained when laws or regulations require it. We have agreements in place with all third parties that ensure your rights under GDPR.

The GDPR primarily applies to controllers and processors located in the European Economic Area (the EEA) with some exceptions.

GDPR restricts transfers of personal data outside the EEA, or the protection of the GDPR, unless the rights of the individuals in respect of their personal data is protected in another way, or one of a limited number of exceptions applies.

A transfer of personal data outside the protection of the GDPR (which we refer to as a ‘restricted transfer’), most often involves a transfer from inside the EEA to a country outside the EEA.

13. AUTOMATED DECISION MAKING

The GDPR has provisions on automated individual decision making (making a decision solely by automated means without any human involvement); and profiling (automated processing of personal data to evaluate certain things about an individual). PingPong does not use automated decision-making processes.

14. DO WE MAKE UPDATES TO THIS POLICY?

In Short:  Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.  

15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO) by email at dpo@pingpongx-eu.com, or by post to:

PingPong Europe SA  

Data Protection Department

Rue du Laboratoire 9

L-1911

Luxembourg   

If you are a resident in the European Economic Area, the "data controller" of your personal information is PingPong Europe SA.  You can contact us directly regarding the processing of your information, by email at dpo@pingpongx-eu.com, or by post to:

Rue du Laboratoire 9

Luxembourg L-1911

Luxembourg 

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by email. We will respond to your request within 30 days.