Privacy Policy - ReactivePay

ReactivePay Tech DOO.

This Privacy Policy includes important information about your personal data and we encourage you to read it carefully.

Welcome

ReactivePay

Software payment solution for financial institutions, banks, payment service providers and B2B customers.

To that end, this Privacy Policy (“Policy”) outlines the “Personal Data” that we collect about you, how we use it, how we share it, your rights and choices, and how to contact us about our privacy practices. This Policy also explains your data subject rights, including the right to object to certain uses of your Personal Data by us.

For the purposes of this Policy, “ReactivePay Tech DOO.”, “we”, “our” or “us” refers to the ReactivePay Tech DOO. entity responsible for the collection and use of Personal Data.

“Personal Data” refers to any information that relates to an identified or identifiable individual, including information that you provide to us or that we collect about you when you engage with our Services (e.g. device information, IP address).

“Services” encompass the products and services that ReactivePay Tech DOO. identifies as being covered by this Policy, including ReactivePay Tech DOO-provided devices and apps. “Business Services” refer to the Services provided by ReactivePay Tech DOO to entities (“Business Users”) who provide us with “End Customer” Personal Data in connection with their own business activities. “End User Services” refer to the Services that ReactivePay Tech DOO. provides directly to individuals for their personal use.

“Sites” refer to ReactivePay Tech DOO cash and the other websites, apps, and online services covered by this Policy. Collectively, Sites, Business Services, and End User Services are referred to as “Services”.

Depending on the context, “you” may refer to the End Customer, End User, Representative, or Visitor:

When you directly use an End User Service for personal use we refer to you as an “End User”.
When you do business with or transact with a Business User, but are not directly doing business with ReactivePay Tech DOO, we refer to you as an “End Customer”.
When you act on behalf of an existing or potential Business User we refer to you as a “Representative”.

Personal Data that we collect and how we use and share itDepending on whether you are an End User, End Customer, Representative, or Visitor, our collection and use of Personal Data varies. For instance, if you are the sole proprietor of a business, we may collect Personal Data to onboard your business. However, you may also be an End Customer who purchased goods from another Business User that uses ReactivePay Tech DOO’s Services for payment processing, or an End User who uses Link to make those purchases.
In this Privacy Policy, “Transaction Data” includes Personal Data, such as your name, email address, billing address, shipping address, payment method information (such as credit or debit card number, bank account information, or payment card image selected by you), merchant and location, purchase amount, date of purchase, and in some cases, information about what you have purchased and your phone number and past purchases.
1. End UsersWe offer End User Services directly to you for personal use. We collect Personal Data, such as your name, contact informations.
  We share this Personal Data with Business Users that you choose only with your separate permission. You may ask us to stop collecting and sharing this information. We also share contact information, phone number, with Business Users that you do business with, but only with your separate permission.
  
  We use your Personal Data to provide the End User Service to you, including security, sanctions screening, support, personalization (e.g., settings choices), and messages related to the End User Service (e.g., communicating Policy updates and information about our Services).
2. End CustomersReactivePay Tech DOO provides Business Services to our Business Clients. When we act as a Business User’s service provider (also known as a data processor), we will process Personal Data in accordance with our agreement with the Business User and the Business User’s lawful instructions.
  1. Collection of Personal Data from End Customers by ReactivePay Tech DOO.
  2. Our use and sharing of Personal Data of End Customers
    To provide our Business Services to Business Users, we require Personal Data from End Customers, and we share such data with the Business User. We also use End Customers’ Personal Data forReactivePay Tech DOO’s own purposes, where allowed by law, to enhance, secure and provide our Business Services and to prevent fraud, loss, and other harms as explained below.
3. Representatives
  To provide Business Services, we collect, use and share Personal Information from Representatives of Business Users (e.g. a business owner).
  1. How we use and share Personal Data of RepresentativesBusiness Services: In order to provide the Services requested by you or the Business User you are associated with, we may use and share your Personal Data with the Business User. For instance, for tax Business Services, we may use your Personal Data to file taxes on behalf of the Business User. Similarly, for our Atlas business incorporation services, we may use your Personal Data to file documents with government authorities on your behalf.
    We may also share your Personal Data with parties authorized by the Business User to receive such information. For example, payment method providers such as Visa and require merchant onboarding information for Business Users that accept their payment methods. ReactivePay Tech DOO will provide the necessary information, including the Personal Data of Representatives, to such financial partners. The use of your Personal Data by authorized third parties is governed by their own privacy policies.
    
    If you have chosen a company name that includes Personal Data, such as a sole proprietorship or a family name, we will use and share that information as any company name would be used in connection with the provision of our Services.
4. Visitors
  We collect, use and share Personal Data of Visitors (who are not End Users, End Customers or Representatives).
  1. Visitor Personal Data that we collect
    Upon visiting our Sites, your Personal Data may be obtained through your submission or our use of cookies and related technologies.
    If you complete a form found on the Site or on third-party websites featuring our advertising (such as LinkedIn or Facebook), we collect the information provided in the form, such as your contact information and any details related to your inquiries regarding our Services. We may also assign a location to your visit.
  2. How we use and share visitor Personal DataPersonalization: The information we collect from cookies and similar technologies is used to personalize your experience on our Sites, improve navigation, and make content about ReactivePay Tech DOO and our Services more relevant to you. This includes tailoring our responses to your region, as some of our Services may not be available in all areas.
    Advertising: We may use and share Visitor Personal Data with others to advertise and market our Services to you, in accordance with applicable law and consent requirements. This includes interest-based advertising and email campaigns, with the aim of measuring the effectiveness of our ads. Please see our Cookie Policy for more information. We do not sell or share Visitor Personal Data to others for their advertising purposes.
    
    Engagement: When visitors interact with our ReactivePay.com site, we may use the information we collect from your devices to provide opportunities for you to engage in conversations or chat with chatbots, in order to address your questions.
More ways we collect, use and share Personal Data
In addition to the ways we collect, use and share Personal Data that are described above, we also process your Personal Data as follows:
1. Personal Data Collection
  The information we gather depends on the Service you use and how Business Users implement our Business Services. We may collect information about devices and browsers used on our Sites and Third-Party Sites, as well as usage data associated with those devices and browsers, such as IP address, language, time spent on the Sites and Third-Party Sites, pages visited, links clicked, payment methods used, and referral sources. We may also use activity indicators, such as mouse activity, to detect fraud. Please refer to our Cookie Policy for more information. We may also collect information you provide to us through various channels, such as support tickets, emails, or social media. When you respond to our emails or surveys, we collect your name, email address, and any other information you choose to include. If you call us, we collect your phone number and any other information you provide during the call. We also collect engagement data, such as your attendance or registration for ReactivePay Tech DOO events and any interaction with ReactivePay Tech DOO personnel. Finally, if you post content on our Sites, we will collect any Personal Data that you provide.
2. Personal Data Usage
  In addition to the Personal Data usage described above, we use Personal Data in the following ways:Enhancing and Developing Services: We utilize analytics on our Sites to examine your usage of our Sites and Services, as well as troubleshoot any technical problems. If you want to know more about cookies that may be served through our Sites and how you can control our use of cookies and third-party analytics, please refer to our Cookie Policy. We also gather and process Personal Data via our different Services to enhance our Services, create new Services, and support our initiatives to make our Services more relevant and valuable to you. For additional information, see our resources.
  
  Communication: We will use the contact information we have about you to provide the Services, which may entail sending codes via SMS to authenticate you. If you are an End User, Representative, or Visitor, we may communicate with you via the contact information we have about you (e.g. using email, phone, text message, or videoconference) to offer details about our Services and our affiliates’ services, invite you to participate in our events or surveys, or otherwise interact with you for our marketing objectives, as long as we do so in compliance with relevant laws, including any consent or opt-out conditions. For instance, we may use the information you submit to us when you provide your contact information or when we collect your business contact information at trade shows or other events to follow up with you regarding an event, send you information you requested about our products and services, and include you in our marketing campaigns.
  
  Social Media and Promotions: If you decide to provide us with Personal Data to participate in an offer, program, or promotion, we will utilize the Personal Data you provide to administer the offer, program, or promotion. We will also use that Personal Data and the Personal Data you make available on social media to market to you unless we are prohibited from doing so.
  
  Preventing Fraud and Ensuring Security: Our Services collect and utilize Personal Data to help us detect and manage fraudulent and malicious activity across our platform, enabling our fraud detection Business Services and securing our Services and transactions against unauthorized access, use, modification, or misappropriation of Personal Data, information, and funds. To prevent and monitor fraud and security compliance, we receive information from service providers, third parties, and our own Services. In some cases, we collect Personal Data from Business Users, financial parties, and third parties. For instance, we may receive information from third parties about compromised IP addresses to protect our Services. This Personal Data helps us confirm identities, perform credit checks in accordance with applicable laws, and prevent fraudulent activity. We may also employ technology to assess the risk of fraud associated with attempted transactions by End Customers or End Users with Business Users or financial partners.
  
  Compliance with Legal Obligations: We utilize Personal Data to meet our contractual and legal obligations related to anti-money laundering, KYC laws, anti-terrorism, export control, and other legal requirements. Our goal is to provide secure and compliant Services, and the collection and use of Personal Data is crucial to this effort. For example, we monitor payment transaction patterns and other online signals to minimize the risk of fraud, money laundering, and other harmful activity to ReactivePay Tech DOO, our End Users, and their End Customers.
3. Personal Data Sharing.
  In addition to the ways described above, we share Personal Data in the following ways:
  We may share your Personal Data with other ReactivePay Tech DOO affiliated entities for purposes outlined in this Policy.
  To provide the Services to our Business Users and End Users, as well as to communicate, market, and advertise to Visitors, Representatives, and End Users regarding our Services, we rely on service providers or processors. These service providers offer critical services such as hosting, analytics, customer service, and auditing. We authorize these service providers to access and use the Personal Data we make available to them for providing the services we require, and to comply with applicable legal requirements. We require our service providers to contractually commit to protect the security and confidentiality of the Personal Data they process on our behalf. Most of our service providers are located in the European Union, Eurasia, Asia,North America .
  In some cases, we may refer you to third parties to obtain services. In such cases, we will disclose the identity of the third party and the information that will be shared with them and seek your consent to share the information.
  If we undergo a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets, or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity that acquires us or part of our business will have the right to continue using your Personal Data, but subject to the terms of this Policy.
  Finally, we may share your Personal Data as we believe necessary to comply with applicable law, to enforce our contractual rights, to secure or protect the Services, rights, privacy, safety, and property of ReactivePay Teach DOO, you or others, and to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
Legal bases for processing data
For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data.
1. Contractual and Pre-Contractual Business Relationships.
  We process Personal Data for the purpose of entering into business relationships with prospective Business Users and End Users and to perform the respective contractual obligations with them. Activities include:
  - Creation and management of ReactivePay Tech DOO accounts and ReactivePay Tech DOO account credentials, including the evaluation of applications to commence or expand the use of our Services;
  - Creation and management of ReactivePay Tech DOO Checkout accounts;
  - Accounting, auditing, and billing activities;
  - Processing of payments, including fraud detection, loss prevention, optimizing valid transactions,
    communications regarding such payments, and related customer service.
2. Legitimate Interests.
  We process Personal Data based on our legitimate business interests, where allowed under applicable law.
  The following is a list of business purposes for which we have a legitimate interest in processing your data:
  - Detect, monitor, and prevent fraudulent and unauthorized payment transactions.
  - Reduce financial loss, claims, liabilities, or other harm to our customers, users, and ReactivePay Tech
    DOO.
  - Determine eligibility for and offer new ReactivePay Tech DOO products and services.
  - Respond to inquiries, send service notices, and provide customer support.
  - Promote, analyze, modify, and improve our Services, systems, and tools, and develop new products
    and services.
  - Manage, operate, and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets.
  - Analyze and advertise our Services, and related improvements.
  - Conduct aggregate analysis and develop business intelligence that enable us to operate, protect,
    make informed decisions, and report on the performance of our business.
  - Share Personal Data with third-party service providers and business partners that help us operate and
    improve our business.
  - Enable network and information security throughout ReactivePay Tech DOO and our Services.
  - Share Personal Data among our affiliates.
3. Consent.
  We may rely on consent to collect and use Personal Data in order to communicate with you and provide our Services. When we process data with your consent, you have the right to withdraw your consent at any time without impacting the lawfulness of the processing prior to the withdrawal.
Your rights and choices
You may have choices regarding our collection, use and disclosure of your Personal Data:
1. Your data protection rights
  In accordance with applicable law, depending on your location, you may have certain rights related to the Personal Data thatReactivePay Tech DOO holds about you. These rights are as follows:
  - The right to request confirmation of whether ReactivePay Tech DOO processes your Personal Data and obtain a copy of that data if it is being processed;
  - The right to request that ReactivePay Tech DOO correct any inaccurate, incomplete, or outdated Personal Data;
  - The right to request thatReactivePay Tech DOO delete your Personal Data in certain circumstances as provided by law;
  - The right to request thatReactivePay Tech DOO limit the use of your Personal Data in certain circumstances whileReactivePay Tech DOO considers another request that you have submitted;
  - The right to request that ReactivePay Tech DOO transfer your Personal Data to another company
    where technically feasible;
  - If your Personal Data is processed based on your consent, the right to withdraw your consent at any
    time;
  - If ReactivePay Tech DOO processes your Personal Data based on legitimate interests, the right to
    object to the processing of your data. ReactivePay Tech DOO will stop processing your data unless
    there are compelling legitimate grounds or legal reasons for the processing;
  - The right not to be discriminated against for exercising these rights; and/or
  - The right to appeal any decision by ReactivePay Tech DOO relating to these rights.
Security and retentionWe take reasonable measures to safeguard the security of your Personal Data, appropriate to the level of risk associated with its processing. We maintain administrative, technical, and organizational controls to prevent unauthorized access, destruction, loss, alteration, or misuse of the Personal Data governed by this Policy. However, please note that no data transmission or storage system can be completely secure.
To assist us in protecting your Personal Data, we recommend that you use a strong password, secure it against unauthorized use, and avoid using the same login credentials (such as password) for ReactivePay Tech DOO accounts and other services or accounts. If you suspect that your interactions with us are no longer secure (for example, if you believe that the security of your ReactivePay Tech DOO account has been compromised), please contact us immediately. You can find more information here.

We retain your Personal Data as long as we are providing Services to you or our Business Users (as applicable), or as long as we reasonably anticipate providing the Services. Even after we stop directly providing Services to you or a Business User you transacted with, or even if you close your ReactivePay Tech DOO account or complete a transaction with a Business User, we may keep your Personal Data for:
- compliance with our legal and regulatory obligations,
- conducting fraud monitoring, detection, and loss prevention activities,
- fulfillment of our tax, accounting, and financial reporting obligations,
- meeting our contractual commitments to our financial partners (and where data retention is required
  by the payment methods you used), and
- compliance with any limitation periods and records retention obligations under applicable law. You
  can find more information here.
International data transfersAs a global company, we may transfer your Personal Data to countries other than your own, including to the Serbia, where data protection regulations may differ from those in your country. To ensure compliance with relevant data protection laws, we take steps when transferring data across borders. In some situations, we may be obligated to disclose Personal Data in response to lawful requests from officials, such as law enforcement or security authorities.
- If applicable law requires a data transfer mechanism, we utilize one of the following: transfers to specific countries or recipients that have been recognized as providing an adequate level of protection for Personal Data under applicable law, EU Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Addendum issued by the Information Commissioner’s Office, or other legal methods available to us under applicable law. While ReactivePay Tech DOO, previously relied on the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield frameworks for the transfer of Personal Data to the United States, we are currently not relying on these frameworks.
Updates and notificationsWe reserve the right to modify this Policy at any time to reflect new services, changes in our privacy practices, or changes in applicable legislation. The notation “Last updated” at the top of this Policy shows when it was last altered. Any modifications become effective when we post the amended Policy on the Services or provide notice of the update as required by law.
- We may send you disclosures and notifications about the Policy or Personal Data gathered by posting them on our website and, if you are an End User or Representative, by contacting you via your ReactivePay Tech DOO Dashboard, email address, and/or physical address provided in you ReactivePay Tech DOO account.
Contact us
- If you have inquiries or concerns regarding this Policy, don’t hesitate to reach out to us at sales@reactivepay.com. If you’re an End Customer, which refers to an individual conducting business or transactions with our client, kindly refer to the privacy policy or notice of the client to obtain information about their privacy practices, options, and controls, or you may directly contact the client.