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Personal Data provided/ obtained and processed
- Contact information of (applicant) Merchant's representatives – name, business address, business email, business phone number, for the purpose of interaction and communication with the (applicant) Merchant in the process of Merchant Acceptance.
- Information of UBOs and legal representatives (Directors) – name, address, ID, for the purpose of Smart2Pay's compliance with applicable laws, with an emphasis on financial supervision legislation and those combatting money-laundering and terrorism financing and the aim to verify the identity of the Merchant's UBOs and Directors.
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Legal basis
- The processing of the elements of personal data referred to above is necessary for Smart2Pay's compliance with the legal obligation to safeguard the security and integrity of the financial sector, including detecting, preventing, investigating and combating (attempted) (criminal or objectionable) conduct directed against the sector of which Smart2Pay forms part, Smart2Pay itself, its Merchants and their Payers and customers and (ii) Smart2pay's compliance other applicable laws such as the Dutch Money Laundering and Terrorist Financing (Prevention) Act ('Wwft').
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Recipients
- Authorities – such as the financial intelligence unit, the police or other authorities if required by law, in particular the Dutch anti-money laundering and counter-terrorist financing act
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Storage period
- As required by applicable laws, in particular the Wwft: 5 years
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Personal data processed for Merchant Acceptance and the related data subjects' rights
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NOTE: Smart2Pay must store the personal information obtained in the process of Merchant Acceptance and monitoring in compliance with the Wwft for a period of 5 years. Smart2Pay will not erase the personal data before a period of 5 years has passed since the last transaction was processed by Smart2Pay.
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Right to access, right to rectification and right to erasure
- As part of the Merchant Agreement, to the terms of which the (applicant) Merchant is bound per the moment of submitting its application, the (applicant) Merchant warrants that the data and information provided in the process of Merchant Acceptance is true, accurate and up-to-date. Therefore there are no reasons justifying and thus no options for the applicant Merchant enabling its exercise of these rights.
- All data and information of applicant Merchants who were not accepted, will be deleted from Smart2Pay's systems, subject however to Smart2Pay's storage requirements under the Wwft.
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