Last updated 20/02/2023
1. How do we process your personal data?
MANGOPAY group companies listed in the preamble run multiple marketing activities simultaneously and jointly administer the Website, in order to best address your contact requests and offer you information about our services. Because of that, the marketing processes are highly centralized and group companies are acting as joint controllers with respect to your personal data collected through the Website. As a result, the companies jointly determined their respective responsibilities for compliance with data protection obligations. In particular the group companies have decided that MANGOPAY SA is responsible for:
- collecting consent for processing of personal data for future marketing and for communication with individuals on behalf of all the joint controllers;
- fulfilling information obligation on behalf of joint controllers;
- ensuring legal basis for data transfer outside the EEA, should group companies decide to entrust the processing of data in the marketing database to an entity in a third country;
- conclusion of data processing agreements when data are entrusted to processors for hosting purposes;
- acting as a common point of contact for individuals whose data is processed.
All the other obligations remain with individual group companies as data controllers.
In order to make contact with you possible, the Website enables collection of certain personal data, among others: name and surname, the company you work for, your corporate email address and/or phone number, as well as any personal data you might include in our free-text fields (such as job title). If you choose to contact us through email, we will also process the personal data you provided us with in the message. MANGOPAY is the controller of your personal data and takes appropriate steps to ensure security of your data.
We process your data collected through the Website for general marketing purposes: (i) responding to your query and to messages sent by you; and (ii) sending you marketing -mails and contacting you telephonically, provided that you consented to such forms of communication.
In processing your data, we pursue our legitimate interest in direct marketing of our own services, which constitutes the legal basis for processing of your data - especially insofar as we are responding to your contact request made through the Website. We may also send you further marketing communication based on your consent to receive marketing materials from MANGOPAY. The consent can be withdrawn at any time, which does not impact legality of processing conducted before withdrawal.
We may also send marketing communication on behalf of our group companies:
(i) Nethone sp. z o.o. with its registered seat in Poland, at ul. Prosta 20, 00-850 Warsaw, Poland.
The legal basis in such case will either be consent (which can be withdrawn at any time, which shall not impact legality of the processing conducted prior to such withdrawal) or our legitimate interest in fostering interest of our group companies, who jointly with us offer complementary services which constitute part of our product offering and can enhance functionalities of MANGOPAY services offered to you.
Provision of your personal data is voluntary, but if you don’t provide us with your basic contact details (name, surname and either phone number or e-mail address), we will not be able to respond to your query.
You have the right to object to the processing of your data based on legitimate interest. You also have the right to request that we correct or delete your data. If you file such a request we will stop processing your data and delete it, unless there exists an important overriding legal interest (e.g. defense of claims or existence of a legal obligation to retain the data) which will entitle us to keep your data for a longer period. You also have the right of access to your data, as well as the right to data portability and to restriction of processing.
We process your personal data only for as long as necessary for the purposes, for which it was collected. In establishing the retention period for your personal data, we take into account, among others, the following criteria: (i) whether you express continuous interest in our services, (ii) if you have become our customer, (iii) if you told us during the call or in a message that you would like us to contact you in the future. The standard retention period adopted by MANGOPAY for processing of data for marketing purposes is 3 years as of the date of the last contact or interaction with you.
We may have to share your personal data with competent authorities (in particular the police or prosecution service), if they approach us with such a request, provided that there exists an appropriate legal basis for making your personal data available to them (e.g. a court order).
If you have any questions with regard to the processing of your data by us or if you wish to exercise your rights, you can contact our data protection officer at firstname.lastname@example.org. You also have the right to file a complaint to the Luxembourg data protection authority by clicking here.
2. What are cookies?
A cookie is a small piece of code that’s automatically saved on your device (computer, phone, tablet or any other device you may be using) when you visit a site. Cookies are stored in your browser and can be managed from the browser level. Cookies have limited lifespan, depending on the type of information collected and its purpose (for more information please see Section 5 below). Cookies can only retain text, which is confidential and in most cases encrypted. Cookies do lots of different jobs, such as allowing you to navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies can remember your actions and preferences over time so that you can easily resume where you left off. Depending on your cookie settings and consents expressed through the cookie banner, cookies and similar technologies can also remember your registered login details and preferences with the purpose of delivering a personalised, reliable and frictionless user experience, as well as help to ensure that adverts you see online are more relevant to you and your interests.
Persistent vs. session cookies
Persistent cookies - these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies - these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
For more information and to make changes to your preferences, please refer to OneTrust cookie management / preference center by clicking on the link in the footer of the Website
3. What are the “similar technologies”?
- Web beacons (also known as pixel tags) are transparent image files used to monitor your journey around and interact with the Website and its content.
- Device fingerprinting is a technology that allows us to collect information about your device (what browser or operating system you use, plug-ins, time zone, other settings). We use this information to identify you and to ensure the security of our Website.
- Google Analytics is a tool we use in order to calculate visits to our Website, check which functionalities of our Website are used most and improve the operation of the Website. If you wish to learn more about Google Analytics tools and your privacy, please visit the following site: https://support.google.com/analytics/answer/6004245?hl=en. You can also opt-out from Google Analytics by installing a browser add-on available here: https://tools.google.com/dlpage/gaoptout?hl=en-GB.
4. Can I opt-out?
Yes, we provide an opt-out mechanism for you to easily reject our cookies. In order to activate our cookies, we need to obtain your explicit permission for their use, by opting-in directly through our Cookie Preference Center which automatically appears once you enter our Website. Please note that some cookies (such as strictly necessary cookies, session cookies or functional cookies) may not require your consent and are necessary for provision of Website services to you. To learn more about cookie settings and the opt-out mechanism, please refer to the “How to disable cookies via the Cookie Preference Center” section below.
5. What type of cookies do we use?
Below you can find an exhaustive list of all the cookies used by us and how we use them.
6. Which cookies can be deposited by third parties?
7. How to disable cookies via the Cookie Preference Center
8. Where can I get further information?