‍Who We Are

Gersha Limited (“PGWay”, “We”, “Us”, “Our”) is a limited liability company incorporated and registered under the laws of Cyprus, having its registered office at Archiepiskopou Kyprianou & Agiou Andreou, 1, Loucaides Building, 2nd floor, Flat/Office 21, 3036, Limassol, Cyprus.

This Privacy Notice describes the Personal Data we collect, how we use and share it, along with details on how you can reach out to us with privacy and data protection-related inquiries.

When you are acting on behalf of a Merchant wishing to utilise our services, we will refer to you as a representative.

When you do business with a Merchant, but do not do business directly with PGWay, we refer to you as an end customer.

Information we collect about you

1. Representative

PGWay in its capacity as a data controller may collect the following personal data about you through our website, Merchant Application Form, or any other platform we make available to you.

The Personal Data collected is used for the following purposes:

• Creation of an account to access PGWay’s services;
• Onboarding process, including compliance review and approval processes based on our internal policies; 
• Generate the necessary documentation to finalise the business relationship and provide you with contracted services;
• To make clarifications for the prevention of money laundering, detect fraud or illicit acts against you or PGWay;
• Conduct legal reviews and due diligence;
• Communicate with you in order to fulfill our obligations under the Gateway Services Agreement;
• Carry out all types of analysis to improve the services offered by PGWay;
• Marketing, advertising or commercial prospecting purposes with respect to the services we offer, our own or those of third parties;
• Conduct service surveys, with the aim of evaluating and improving the quality of the products and services we offer; and
• Comply with the legal obligations of PGWay.

2. End Customer

PGWay provides a technical gateway for payments to Merchants directly, acting as a Data Processor to them. Merchants are responsible for ensuring the privacy rights of their end customers, including ensuring proper disclosure of data collection and processing that occurs in connection with the Services. If you are an end customer, please refer to the Merchant's privacy notice for information on the processing of your data.

The Merchants may provide personal data to us directly or indirectly through our programming interface, email, or any other designated platform. Personal data provided to us may include the following:

• Contact information including full name, email address, telephone, address, country, city, gender
• Transaction data including date, amount, payment method, status.

We process this information for several purposes including but not limited to transaction processing, fraud detection and money laundering prevention, addressing complaints and claims, and complying with legal obligations. 

‍Legal Basis for Processing

‍PGWay is committed to protecting your privacy and handling your personal data in a lawful, fair, and transparent manner in compliance with the EU General Data Protection Regulation. We will process your personal data when we have a lawful basis to do so. The lawful basis we may rely on include:

1. Contractual and pre-contractual business relationships: We process personal data for the purpose of entering business relationships with potential Merchants and to fulfill the respective contractual obligations we have with such entities.
2. Legitimate business interests: We may process personal data for the purpose of our legitimate business interest including improving our Service offerings and ensuring the security of our platforms and Services. 
3. Consent: Based on the consent you provide to us to process your personal data in your capacity as a representative of a Merchant.
4. Legal Obligation: We may process your personal data in order to fulfill legal obligations and requirements from applicable laws including Anti-Money Laundering and Counter Terrorism Financing Regulations

Recipients of your information

‍PGWay may share personal data with third-parties in cases that are necessary as required by law, or if we are authorized under contractual obligations and statutory obligations, or if we have your consent. Categories of recipients of Personal Data may include;

• Regulatory, supervisory, and other public authorities when a statutory obligation exists
• Service providers who assist us with the effective provision of our services
• External legal, financial, and business advisers
• Card processing companies, gateway providers, payment service providers
• Fraud prevention agencies
• Marketing and Advertising business partners

International Data Transfer

‍Personal Data may be transferred outside the EU/EEA area if such transfer is necessary and there is a lawful basis for the transfer. Any personal data transferred to other countries will be treated with the same level of protection, in compliance with the guarantees required by applicable legislation and under the security policies of PGWay.

‍Data Security

‍We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical, and administrative measures designed to protect the Personal Data covered by this notice from unauthorized access, destruction, loss, alteration, or misuse. The Internet, by its nature, cannot ensure complete security of data transmission or storage. While we strive to protect your personal information, we cannot guarantee its absolute security. However, we will continuously assess and improve our security practices to enhance the protection of your data.

‍Your Rights

‍You have rights regarding your personal data, including:

• Right to access
• Right to rectification
• Right to erasure (right to be forgotten)
• Right to restrict processing
• Right to data portability
• Right to object
• Rights related to automated decision-making and profiling

To exercise these rights, contact us at dpo@pgway.com.

‍Cookies

‍We use cookies and similar tracking technologies on our website. Please see our Cookie Notice for more information.

‍Data Retention

‍We will keep your data only for the period strictly necessary for the respective purposes of the processing or for a period determined by legal requirements and our legitimate business interests.

‍How to Contact Us

‍For privacy and data protection-related inquiries, email us at dpo@pgway.com or support@pgway.com.

‍Changes to our Privacy Notice

‍We may update this privacy notice occasionally to keep up with changing legislations, best practices, and the way we process your personal data. Any changes will be immediately placed on our website. We recommend that you check this page regularly to keep up to date.

Version 1.0

July 2024

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‍Cookie Notice

Introduction

‍This Cookie Notice builds on our Privacy Notice by explaining how we use cookies and similar technologies to manage and deliver our online services and electronic communications to you. We will explain what these technologies are, why we use them, and how you can control our use of them.In some cases, these cookies and technologies might collect personal data, or information that becomes personal data when combined with other information we have. To understand more about how we handle your personal data, please refer to our Privacy Notice.

‍What are Cookies and Tracking Technologies?

‍Our website uses cookies - small files downloaded to your device that help us and our third-party partners gather information about your interactions with our websites, email communications, and other online services to improve your experience. We and our third-party partners and providers  may also use other similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies, and logging technology (collectively called “cookies”).

‍Our Use of Cookies

‍We, along with our partners, use cookies to gather information about how you interact with our websites, emails, and other online services. This helps us improve your experience and understand how people use our services.

‍The kind of information we collect automatically includes:

• Details about your device and software (operating system, browser type).
• When you visit and how you use our services (pages viewed, time spent).
• We may track email opens and clicks to see if you received and interacted with our emails with your consent.
• We may also use analytics tools to see usage trends and understand our user base.
• Information about your location may also be collected based on your IP address.

Types:

Essential Cookies: These are crucial for basic functions like security and navigation. Turning them off will affect how our website works. We use these because it's in our legitimate interest to provide and maintain our website and services.

‍Functional Cookies: These remember your choices (such as language, region) to personalize your experience. The legal basis for these is our legitimate interests in providing and maintaining our services.

‍Performance Cookies: These help us recognize and count visitors, and understand how you navigate our services. This helps improve our services by ensuring you can easily find what you need. We will only use these cookies with your consent.

‍Targeting Cookies: These cookies record your visit to our website, the pages you visited, and the links you followed, and are used to track visitors. We will ask for your consent to use these cookies. You are free to deny this consent.

‍Sources:

First-Party Cookies: These cookies are created by our website and can only be accessed by us. They are typically used to remember your preferences (language, location) and improve your experience on our services.

‍Third-Party Cookies: These cookies are placed on your device by other companies (third-party partners) whose services we integrate into our website. These cookies are used for various purposes, such as analytics, advertising, and social media integration.Duration:Session Cookies: These cookies are temporary and are automatically deleted when you close your browser.

‍Persistent Cookies: These cookies remain on your device for a predetermined period of time (set by the cookie itself or by us) even after you close your browser.

‍Why We Use Cookies

‍We use cookies for various reasons, which can be broken down as follows:

• Set you apart from other users on our sites, ensuring you have a great browsing experience and helping us enhance our sites.
• Gain a better understanding of your preferences to display advertisements that match your interests based on your activity on our sites.
• Collect data on how our Services are used to improve our offerings.
• Improve site security by preventing fraud and abuse.
• Identify your preferences and track your activity to ensure the site functions smoothly and the content you see is personalized and accurate.
• Keep track of your language choice, browsing activity, browser type, device, and favorite products to present relevant content to you.
• Deliver the right information based on how you accessed the site, whether through a search engine or an affiliate network.

Managing Your Cookie and Advertising Preferences

‍You have choices when it comes to cookies and their use for advertising! Here's how you can manage them:

‍Browser Settings

‍Most browsers allow you to adjust your cookie settings in several ways, including:

• Get alerts when a cookie is sent, letting you decide to accept or reject it.
• Remove cookies already stored on your device.
• Set your browser to automatically reject all cookies.

Please note that disabling cookies may negatively affect the functionality of this and other websites you visit, potentially leading to reduced functionality and features of our website. You can limit interest-based ads displayed on your current browser by visiting optout.aboutads.info or networkadvertising.org/choices.

‍Mobile Devices

‍You can enable the "Limit Ad Tracking" setting on iOS or the "Opt out of Ads Personalization" setting on Android.

‍Email Settings

‍You can also configure your email settings to prevent the automatic downloading of images, which can contain technologies that inform us if you have accessed our email and performed certain actions with it.

‍Google Analytics & Ads

‍Opt out of Google Analytics by installing their browser add-on and manage interest-based Google ads through their Ads Settings.

‍Interest-Based Advertising 

Block ads based on your browsing habits by visiting http://www.youronlinechoices.com.

Depending on your device and operating system, you might not be able to delete or block all cookies. Additionally, if you wish to reject cookies across all browsers and devices, you will need to adjust the settings on each browser and device you use. 

‍Learn More About Online Advertising

‍Here are some resources to understand how advertisers use cookies and your choices:

• Digital Advertising Alliance (General Information)
• European Interactive Digital Advertising Alliance (EU-Specific Information)
• www.aboutcookies.org (Information on Deleting or Controlling Cookies)

Contact Us

‍If you have any questions or complaints about our use of cookies or this Cookie Notice, you may contact our Data Protection Officer by sending an email to dpo@pgway.com.

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