Cookies & Privacy Policy

Effective as of 01.12.2015

This cookie and privacy policy (Policy) describes the types of personal data Pocopay collects, how Pocopay use Client’s personal data, with whom Pocopay share Client’s personal data, how Pocopay store and protect Client’s personal data and how Client can contact Pocopay regarding privacy practices.

Client accept the terms and conditions of this Policy by visiting Pocopay website or using Pocopay mobile application.

Herein, “Pocopay” refers to the data controller, AS Pocopay, registry code 12732518, a public limited company incorporated under the laws of the Republic of Estonia, with the address Pärnu rd 102c, Tallinn, 11312.

“Client” are the data subject, client of Pocopay.

1. Personal data Pocopay process

For the purposes described in Section 2 of the Policy Pocopay process primarily but not only the following data about Client: name, date of birth, personal identification code, information regarding an identity document (incl. nationality), Client’s residency, information required by law (e.g. information about origin of Client’s assets, purpose of the business relationship etc.), Client’s preferences regards Pocopay services and products, e-mail address, physical address, information about Client’s work or study, habits, preferences and satisfaction, Client’s device-ID, IP-address, Client’s geo-location, credit and debit card information, payment details, Client’s IBANs and other bank and payment account related details (incl. balance, logs, transactions), phone number and any other data Client provide to Pocopay, whether intentionally or unintentionally.

2. The purposes of processing Client’s personal data

Pocopay process Client’s personal data described in Section 1 for the following purposes:

  • to process Client’s payment and service requests and transactions either on Pocopay own or together with partners of Pocopay
  • to protect against and prevent fraud and unauthorized transactions either on Pocopay own or together with partners of Pocopay
  • to create and manage Client’s account either on Pocopay own or together with partners of Pocopay
  • to offer Client new services either on Pocopay own or together with other financial institutions or partners
  • to issue payment instruments
  • to analyse the use of Pocopay or its partner services and make improvements thereof
  • to administer Pocopay’s website and mobile application(s)
  • to comply with the regulatory requirements and requests of the supervisory and law enforcement authorities
  • to respond to Client’s or Pocopay partner inquiries
  • to comply with industry standards and policies
  • to provide information about Client and Client’s transactions and use of services to partners of Pocopay (e.g. for loyalty programmes)

3. Sharing and storing personal data

Pocopay may share Client’s personal data with subsidiary companies of Pocopay, all located within the European Union. Also, Pocopay may share Client’s personal data with selected financial institutions and business partners for the purposes set out in Section 2. If required under applicable law, Pocopay will share Client’s personal data with law enforcement agencies.

The full list of persons with whom Pocopay share Client’s personal data and who process Client’s personal data on Pocopay behalf is accessible here.

Pocopay will not store Client’s personal data outside the European Economic Area and in countries which have not received the European Commission’s “adequacy decision” on the basis of Article 25(6) of Directive 95/46/EC.

Pocopay have taken appropriate technical, physical and organisational security measures against the loss and unlawful processing of Clients personal data.

4. Cookies

Pocopay use cookies on Pocopay website. Cookie is a small text file, which is placed automatically on Client’s device by the Internet browser. Cookies are used to assist in collecting information associated with Client’s use of the website in order to personalise Client’s use of Pocopay website. Pocopay uses the following cookies:

  • session cookies for the purpose of enabling the use of Pocopay service;
  • permanent cookies for the purpose of remembering Client’s choices on Pocopay website;
  • first and/or third party (advertising) cookies for the purpose of showing Client relevant advertising and offers;
  • third party analytics cookies for the purpose of optimising marketing communication.

Client may disable cookies being stored on Client’s device by changing Client’s browser settings. However, as a result, Pocopay website may not function properly and/or some features may not be available to Client in that case.

In addition to using analytics cookies, Pocopay use pixel tags and web beacons for the purpose of monitoring the use of Pocopay website. Pocopay do not process any personally identifiable information in that regard.

5. Client’s rights

Client have the right to access Client’s personal data processed by Pocopay and the right to demand the correction of inaccurate personal data.

If Client have any questions regarding exercising its rights or is of the opinion that Pocopay has breached its rights while processing its personal data, it should contact Pocopay at privacy@pocopay.com. If the solution Pocopay provided is dissatisfying, Client have the right of recourse to the Data Protection Inspectorate of the Republic of Estonia (Andmekaitse Inspektsioon) and the court.

6. Other

Pocopay may unilaterally change this Policy from time to time. The latest version of this Policy is always posted on this page.

Pocopay website may contain links to other websites owned and operated by third parties or Pocopay partners. These websites are out of Pocopay control and Pocopay are not responsible for the content of those websites or any hyperlink contained in those websites. Also, Pocopay website may contain third party advertisements which may contain embedded hyperlinks to the websites of third parties or Pocopay partners. Pocopay exclude any liability regarding the interaction between Client and these advertisement providers.

This Policy is governed by the laws of Republic of Estonia. Any dispute or claim arising out of this Policy will subjected to the Harju County Court in Tallinn, Estonia as the court of first instance.