Global Privacy Notice

This Global Privacy Notice delineates the categories of personal data collected through our payment system and our online presence, including our principal website at cautroma.com. It explicates the utilisation of personal data, delineates your rights and choices, and provides information on how to contact us regarding our privacy practices. It is pertinent to note that this policy is not applicable to third-party websites, products, or services that may link to our services or sites, and we advise a thorough review of the privacy practices of such third-parties.

Overview

Cautroma acquires personal data pertaining to you from multiple sources to furnish our services and oversee our website. You may engage with our website as a visitor or utilise one or more of our services as a user. A visitor is characterised by their activity of browsing our website, during which Cautroma generally does not collect personal data directly from them. Conversely, a Cautroma user, who is a customer that has registered their contact details on our website or directly with the business, provides information including but not limited to name, address, telephone, and email address. Such information, along with additional data, is collected and preserved for the purposes of managing user profiles and security information.

Personal data we collect

a. Personal data that we collect about you.

Any data pertaining to an identified or identifiable individual constitutes personal data, which, when provided directly to us through our Site and Services, will be evident from the context in which you submit the data; in particular:

• i. When you register for a Cautroma account we collect your full name, email address, and account log-in credentials.
• ii. When you complete our online form to engage with our customer service team, we collect your full name, work email, country, and any additional information you provide regarding yourself, your business, your needs, and other pertinent details.

When you respond to Cautroma's emails or surveys, we collect your email address, name, and any additional information you opt to provide in the body of your email or responses. Should you contact us by phone, we collect the phone number utilised to reach Cautroma. Furthermore, if you contact us by phone as a Cautroma User, we may gather further information to confirm your identity.

• If you are a Cautroma User, you are required to provide your contact details, including your name, postal address, telephone number, and email address. In the context of your business relationship with us, we may additionally receive supplementary information pertinent to you, such as your date of birth and government identifiers linked to you and your organisation, including but not limited to your tax number, Employer Identification Number, Company Registration Number, and VAT Registration Number.

In the course of executing fraud monitoring, prevention, detection, and financial compliance activities, or while providing such services to our Users, we will procure personal data from you and about you via our Service merchant service providers, identity verification services, and publicly accessible sources (for example, name, address, phone number, country) as required to verify your identity and avert fraud. Our fraud monitoring, detection, and prevention services may gather personal data concerning you and employ technology to evaluate the risk linked with a transaction you attempt.

You may also choose to submit information to us via other methods, including:

• i. in response to marketing or other communications,
• ii. through social media or online forums,
• iii. through participation in an offer, program or promotion,
• iv. in connection with an actual or potential business relationship with us, or
• v. by giving us your business card or contact details at trade shows or other events.

b. Information that we collect automatically on our site.

Our Site employs cookies and other related technologies to operate efficiently, which involves recording information regarding your utilisation of our Site.

• i. Our Site collects browser and device data, which includes your IP address, device type, operating system and internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Site you are utilising.
• ii. Our Site gathers usage data, which encompasses the duration of your visit, the pages you viewed, the links you clicked on, and your language preferences.
• iii. Cookies are deployed on Cautroma to facilitate continuous access to our service, and it is affirmed that no cookies are utilised to track, monitor, or collect any information for purposes of marketing or advertising.

How we use personal data

a. Our services.

We depend on various legal bases to ensure that our usage of your personal data adheres to the relevant laws. We utilise personal data to streamline the business relationships we maintain with our Users, to fulfill our financial, regulatory, and other legal responsibilities, and to advance our legitimate business interests. Additionally, we use personal data to execute payment transactions and provide services to our Users.

b. Marketing and events-related communications.

We will refrain from sending you email marketing communications regarding Cautroma services. However, we may extend invitations for you to engage in events or surveys aimed at evaluating our services professionally or informing you about changes or enhancements to our services. Should we acquire your business contact details through our involvement in trade shows or similar events, we reserve the right to use this information to follow up with you post-event, provide information you have solicited about our services, and, subject to your consent, maintain further contact.

c. Advertising.

There are no paid advertising campaigns on our Site conducted by third-party companies, and we will not utilise personal data collected from you and your device to target advertisements for Cautroma Services at you on our Site.

We do not employ algorithms of any kind on this site to promote or advertise user information and profiles to other members.

We do not engage in the use, sharing, renting, or selling of the personal data of our Cautroma Users for the purpose of interest-based advertising.

d. Cookies.

Only essential cookies necessary for the fundamental functionality are utilised on the Service; we refrain from using third-party cookies from search engines for tracking analytics or any other purposes.

How we disclose personal data

Cautroma does not engage in the sale or rental of personal data to marketers or unaffiliated third parties and shares your personal data only with trusted entities, as detailed subsequently.

a. What we share.

We disclose personal data to other Cautroma entities for the purpose of delivering our services and for internal administrative purposes.

b. Service Providers.

We disclose personal data to a select number of service providers who render services on our behalf, including but not limited to identity verification, website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, and auditing services. These service providers may access personal data solely for the purpose of performing their services or to fulfill legal obligations. We mandate these service providers to use or disclose personal data only as necessary for executing services on our behalf or to meet legal requirements and obligate them through contractual agreements to uphold the security and confidentiality of personal data processed on our behalf. Our service providers are primarily based in the United Kingdom, European Union, and the United States of America.

c. Business partners.

We disclose personal data to third-party business partners when it is essential to deliver our Services to our Users. For instance, banks and payment method providers, including credit card networks, are examples of third parties to whom we may transfer personal data to facilitate the provision of our Services.

d. Corporate transactions.

In the event of, or intent to enter into, a transaction that changes our business structure, such as reorganisation, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any segment of our business, assets, or stock, we may disclose personal data to third parties in relation to such transaction. Any entity that acquires us or a part of our business will acquire the right to use your personal data, but solely in the manner described in this Privacy Notice unless you consent otherwise.

e. Compliance and harm prevention.

We share personal data as we believe necessary:

• i. to comply with applicable law, or payment method rules;
• ii. to enforce our contractual rights;
• iii. to protect the rights, privacy, safety and property of Cautroma, 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.

Your rights and choices

You have choices regarding our use and disclosure of your personal data:

a. Opting out of receiving electronic communications from us.

We will exclusively send you crucial administrative messages, either directly to your email concerning account-related matters or via the Service Announcements page, where all users are informed of pertinent Service information. You will not receive any unsolicited marketing materials from us.

b. How you can see or change your account personal data.

Should you wish to review, correct, or update personal data that you have previously provided to us, you may do so by logging into your Cautroma account.

c. Your data protection rights.

Dependent on your geographical location and in accordance with relevant legislation, you may possess the following rights concerning the personal data we hold about you:

• i. You have the right to request confirmation from Cautroma regarding whether we process personal data pertaining to you and, if affirmative, to request a copy of such personal data.
• ii. You have the right to request that Cautroma rectifies or updates any personal data concerning you that is inaccurate, incomplete, or outdated.
• iii. You have the right to request that Cautroma erase your personal data under certain conditions as stipulated by law.
• iv. You have the right to request that Cautroma restrict the processing of your personal data under certain circumstances, such as when Cautroma is evaluating another request you have made (including a request for Cautroma to update your personal data).
• v. You have the right to request that we transfer, where technically feasible, your personal data that we hold to another company in order to provide services to you.

Where the processing of your personal data is contingent upon consent you have previously provided, you reserve the right to withdraw that consent at any given time. Additionally, you may possess the right to object to the processing of your personal data based on grounds related to your specific circumstances.

d. Process for exercising data protection rights.

To exercise your data protection rights, you are invited to contact Cautroma directly. We consider each request with utmost seriousness and will adhere to your request in accordance with the obligations imposed by applicable law. Should we no longer retain your personal data, we will be unable to fulfill your request. If you believe our response has not been satisfactory, you are entitled to seek recourse with the data protection authority within your jurisdiction.

For your security, we may require verification of your identity prior to addressing your request, such as confirming that the email address from which the request is sent corresponds with the email address we have in our records. Should there be no necessity to process your personal data for the provision of our Services or for our Site, we will not retain, obtain, or process additional information solely for the purpose of identifying you to respond to your request.

Security and retention

We exert diligent efforts to maintain a level of security commensurate with the risk involved in the processing of personal data. We uphold organisational, technical, and administrative safeguards designed to protect personal data within our organisation from unauthorised access, destruction, loss, alteration, or misuse. Access to your personal data is strictly limited to personnel who require this information to fulfill their job responsibilities. While we strive to ensure the security of our data transmission and storage systems, no system can be deemed entirely infallible. Should you suspect that your interaction with us has become insecure (for instance, if you believe the security of your account has been compromised), we urge you to contact us without delay.

We retain your personal data for as long as we are providing services to you and continue to retain it after ceasing such services, to the extent necessary to fulfill our legal and regulatory obligations, and for the purpose of fraud monitoring, detection, and prevention. Additionally, we retain personal data to adhere to our tax, accounting, and financial reporting duties, to comply with our contractual obligations to our financial partners, and to align with retention mandates of the payment methods we support. When we retain data, it is in accordance with any applicable statutory limitation periods and records retention requirements imposed by law.

International data transfers

Cautroma operates on a global scale, meaning your personal data may be stored and processed in any country where we conduct operations or engage service providers, potentially involving the transfer of personal data to countries other than where it was initially collected. It is acknowledged that these countries may have data protection regulations that differ from those in your country. Nevertheless, we commit to implementing measures to ensure that any such data transfers adhere to applicable data protection laws and maintain your personal data's protection as delineated in this Privacy Notice. Under certain conditions, judicial, law enforcement, regulatory bodies, or security authorities in those countries might have the right to access your personal data.

Use by minors

The services are not intended for individuals under the age of sixteen (16) for general use and are restricted to individuals aged eighteen (18) and above for services subject to age regulatory requirements.

Updates to this Privacy Notice and notifications

We reserve the right to modify this Privacy Notice periodically to accommodate new services, alterations in our Personal Data practices, or changes in relevant laws. Such amendments become effective upon the posting of the revised Privacy Notice on the Services. Notifications and alerts concerning the Privacy Notice or Personal Data collected may be disseminated by posting on our website and, for Cautroma Users, through communications directed to your dashboard, email address, and/or the physical address associated with your Cautroma account.

Links to other websites

The services may offer functionalities to connect to external websites, which operate independently from us and may possess their own privacy notices or policies, which we strongly recommend you to review. We are not liable for the content, usage, or the privacy practices of any linked website that is not owned or controlled by us.