Privacy and Cookie policy
Last updated 11/05/2023
This Privacy and Cookie Policy (hereinafter the “Privacy Policy”) applies to the collection of personal data and use of "cookie" files and similar technologies on the mangopay.com and to other Mangopay sub-sites, including but not limited to:
and/or to their mobile versions (the “Website”).
Mangopay S.A., registered at 2 Avenue Amélie, L-1125 Luxembourg and Mangopay UK Limited, registered at The Smiths Building, 4th floor, 179 Great Portland St, London W1W 5PL, UK (jointly referred to as “Mangopay”, “We”, “Our”, “us”) are joint controllers of your personal data which may be collected through contact forms and through the use of cookies and similar technologies (apart from third-party cookies as described below), as well as administrators of the Website.
By your continued use of our services following the posting of this Privacy Policy (as applicable), you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version.
In order to provide you with up-to-date information and or important reasons, we may periodically be required to make changes to our Privacy Policy (for example if we substantially change the way our services or the Website functions, or following legislative or regulatory changes). We will notify you of these changes by email (if applicable) and/or by posting the modified Privacy Policy on the Website. Therefore, we invite you to regularly consult this Privacy Policy to obtain accurate and up-to-date information regarding our processing of your data and our use of cookies. If we are going to use your personal data in a manner materially different from that stated at the time of collection, we will notify you by e-mail and/or seek your consent. You may determine when this Privacy Policy was last updated by referring to the date found at the top of the first page of this Privacy Policy.
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 contact form on 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 office at Plac Europejski 1, 00-844 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 do not share your data with data controllers other than group companies listed in this Privacy Policy (provided we have a legal basis for such sharing), but we entrust the processing of your personal data to entities, which act on our behalf and solely based on our instructions (data processors). In particular we use data processors, whom we select carefully, to store your data on secure servers, provide us with CRM solutions, technical cookie management tools as well as tracking and analytics solutions and advertising networks. In the event that the personal data is entrusted for processing to service providers outside the EEA, we employ appropriate safeguards, assess trustworthiness of our service providers and conclude Standard Contractual Clauses with them or rely on adequacy decisions issued by the European Commission.
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 dpo.mangopay@mangopay.com. 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.
Mangopay uses cookies and similar technologies (such as web beacons, pixels and analytical tools) to tailor our Website to your interests and needs, to improve its operation and to ensure security, as well as to provide you with the best user experience possible. The types of data we collect while you are browsing the Website include: web browser preferences and settings, technical information about the device you are using and information about your previous interactions with Mangopay's Website.
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 always 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?
For the purposes specified in this Privacy Policy, we make use of our own cookies (or first-party cookies), which are implemented directly by us and readable only by us.
Third-party cookies which may be used on the Website are set and developed by third-parties, such as Facebook, LinkedIn or Google, to implement new features or functionality (e.g. advertising, social sharing etc.). Although these cookies are implemented directly by these third parties for site analytics and marketing purposes, their use is carefully supervised by MangopayMANGOPAY. Third-party cookies and their use is also subject to third party privacy policy.
7. How to disable cookies via the Cookie Preference Center
At any time you can access the Cookie Preference Center by clicking on the link in the footer of each Platform. Through the Cookie Preference Center, you can decide which cookies are active and can be stored in your browser. If you’ve accepted the use of cookies on your device, us and the third-parties implementing their cookies, will be able to process your browsing information as described above. If you reject all cookies, you may not be able to use the services or features that require you to be connected or logged in. You might also not have the possibility of personalising the service delivered to you by us.
You may also be able to manage your cookie preferences directly through your web browser, by setting your web browser controls to accept or refuse cookies. As the means by which you may control cookie acceptance via web browser settings differs from one browser to another, please consult the help section of your web browser or explore the links provided below:
Chrome: https://support.google.com/chrome/answer/95647?hl=en
Safari: https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
Mozilla: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
Opera: https://help.opera.com/en/latest/web-preferences/#cookies
8. Where can I get further information?
If you have any questions about our processing of personal data or use of cookies and similar technologies on our Website, please email us at dpo.mangopay@mangopay.com
