PRIVACY NOTICE FOR MERCHANT & PARTNER STAFF AND WEBSITE VISITORS

1. INTRODUCTION

Welcome to Volt’s general privacy notice. Volt respects your privacy and is committed to protecting your personal data.

This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. It also describes your data protection rights, including a right to object to some of the processing which Volt carries out. More information about your rights, and how to exercise them, is set out in the “Your Legal Rights”’ section.

This notice applies to visitors to the Volt.io website, and Volt partners and merchants (and employees of Volt partners and merchants) who enter into contracts with Volt to facilitate payments for goods and services. The data processing described in this notice may be limited as required by applicable law. Where you are a consumer of Volt’s payment services, we process your data in accordance with our Consumer Privacy Policy.

2. PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Volt collects and processes your personal data when you use this website, when you contact us or subscribe for our marketing, or you (or your employer) signs up to our services, including any data you or your employer may provide through our websites, digital services or within merchant application forms. 

It is important that you read this privacy notice together with any other policies we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

3. CONTROLLER

Volt Technologies ‘Holdings Limited’ is the controller and responsible for your personal data (collectively referred to as “Volt”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

4. CONTACT DETAILS

Our full details are:

Full name of legal entity: Volt Technologies ‘Holdings Limited’

Email: legal@volt.io

Postal address: 42 Berners Street, London, United Kingdom, W1T 3ND

Volt Technologies ‘Holdings Limited’ is registered with the Information Commissioner’s Office (ICO). You have the right to make a complaint at any time to the ICO, the UK’s independent authority for data protection issues (www.ico.org.uk), or to any EU supervisory authority where you live, work or believe a breach to have taken place. We would, however, appreciate the chance to deal with your concerns directly so please contact us in the first instance.

5. YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

6. THE DATA WE COLLECT ABOUT YOU

We may collect your data in different ways. In particular:

Direct interactions by you or your employer 

When you, or your employer, applies for Volt’s products or services you may provide us with information about you by completing and submitting your application form, or providing your authentication details for our digital products.  You or our employer may also provide us with information when you contact us, subscribe for marketing purposes or give us feedback. 

Automated technologies or interactions 

As you interact with our website or digital product, we automatically collect technical data about your equipment, browsing/usage and patterns.  This includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our section on cookies below for further details.

Third Parties

We may receive personal data about you from various third parties and public sources including:

  • where you are an employee of a Volt partner or merchant, we may receive information from your employer relating to your role, responsibilities and access permissions for the Volt products and services we provide;
  • technical data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website from analytics providers and advertising networks; 
  • identity data including first name, last name, title, date of birth; and contact information including your current residential address, previous addresses, email address and telephone numbers from brokers, aggregators and publicly available sources (such as Companies House and the Electoral Register); and
  • where you are an owner or director of a partner or merchant we may collect commercial data including percentage ownership of company (including beneficial ownership), political exposure and any information that is relevant to sanctions as part of our anti-money-laundering and know your customer checks.

7. HOW WE USE YOUR PERSONAL DATA

We will use your personal data in the following circumstances:

  • Where we need to take steps related to the contract we are about to enter into with you or have entered into with you. This includes:
    • managing payments, fees and charges;
    • collecting and recovering money owed to us; 
    • communicating with you;
    • providing customer service; and
    • confirming your identity for the purposes of security and fraud prevention.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. In particular, we:
    • monitor use of our website and use your information to help us monitor, improve and protect our services, including asking you to leave reviews or take surveys related to our products or services;
    • tailor our services to the needs of the merchant (which may be you or your employer), including by implementing contextual or role-based access to customer information in the Fuzebox platform;
    • send you direct marketing, if we do not need your consent;
    • use your information to help us assess and improve the Volt services;
    • respond to any correspondence you may send us;
    • use information you provide as well as information which we have collected about you to investigate any complaints received from you, or from others, about our website, products or services; and
    • use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
  • Where we need to comply with a legal or regulatory obligation. For example: 
    • to discharge our obligations as a regulated financial service provider including ‘know your customer’ checks, anti-money-laundering checks, politically exposed persons checks, sanctions checks; and
    • in response to requests by government or law enforcement authorities conducting an investigation.
  • Where we have obtained your consent, for example we may send you direct marketing communications and place cookies or use similar technologies to read information on your device for non-essential purposes. On other occasions, where we ask you for consent, we will use the data for the purposes we explain at that time.

8. WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO DIRECT MARKETING

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests.  You can ask us to stop sending you marketing messages, at any time by following the unsubscribe links on any marketing message sent to you; or by contacting us. Where you opt out of receiving these marketing messages, this will not affect our processing of data for other purposes (see above).

9. INFORMATION ABOUT OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

What are cookies?

A cookie is a very small text document, which often includes an anonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website’s server. Find out more about the use of cookies on www.allaboutcookies.org. 

We also use other forms of technology which serve a similar purpose to cookies and which allow us to monitor, secure and improve our website and services, such as browser fingerprinting. When we talk about cookies, this term includes these similar technologies. 

What cookies do we use and what information to they collect?

  • Required cookies: these cookies are required to enable core functionality. Without these cookies, services you have asked for, like providing secure payment, cannot be provided. If you disable these cookies, certain parts of the website will not function for you. 
  • Analytics cookies: these cookies help us improve or optimise the experience we provide. They allow us to measure how visitors interact with our website and we use this information to improve the user experience and performance of our platforms. These cookies are used to collect technical information such as the number of pages visited, which parts of our website are clicked on and the length of time between clicks.
Third party cookies

Your use of our website may result in some cookies being stored that are not controlled by us. This may occur when the part of the website you are visiting makes use of a third-party analytics or marketing automation/management tool or includes content displayed from a third party website. You should review the privacy and cookie policies of these services to find out how these third parties use cookies and whether your cookie data will be transferred to a third country. A list of the third parties who place cookies on the website can be found on our Cookie Management Platform.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. You may also control your use of cookies through our Cookie Management Platform. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy.

10. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties below for the purposes described above.

  • Other companies in the Volt Group, who provide IT and system administration services and undertake leadership reporting.
  • Third party service providers (e.g. providing, fraud prevention, IT and admin support services) acting as processors who process the data under our instructions.
  • Third party providers who provide us with ‘know your customer’ services, including anti-money-laundering checks;
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities or law enforcement bodies based in the United Kingdom, the EU or elsewhere if required for the purposes above, or if mandated by law or if required for the legal protection of our or third-party legitimate interests in compliance with applicable laws.

11. INTERNATIONAL TRANSFERS

Some of the third parties who will receive your data are based outside the European Economic Area (EEA) or United Kingdom so their processing of your personal data will involve a transfer of data outside the EEA or United Kingdom.

Whenever we transfer your personal data out of the EEA or United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is in place.

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and equivalent authorities in the United Kingdom, or with whom we have put in place appropriate measures to ensure that data is adequately protected.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA

12. DATA RETENTION

How long will you use my personal data for?

Where we process information about you in connection with our contract with you, or your employer, and the transactions carried out through our services, we process this for six years after you cease being a customer  for legal and regulatory purposes.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). 

We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Where we process your data for other purposes, such as complying with laws or defending our legal position, we process this data for as long as is necessary to fulfil that purpose.

13. YOUR LEGAL RIGHTS

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where it would infringe the rights of a third party (including our rights)  or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. 

We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, you can get in touch with us, or make a complaint, using the details set out above. 

Where we process your data for the purpose of entering or performing a contract with you certain data is mandatory for that purpose. Any information provided to facilitate a payment you have requested is therefore mandatory. Where provision of data is mandatory, if relevant data is not provided, then we will not be able to fulfil your requests to register, make a purchase or otherwise engage with Volt. All other provision of your information is optional.

Brazil Privacy Notice

1. APPLICABILITY 

This section will apply for personal data processing activities performed by Volt for the Brazilian market, which includes any processing activity (i) carried out in Brazil, (ii) aimed at offering or providing goods or services or processing data of individuals located in Brazil, or (iii) collected in Brazil. In this context, any personal data processing activities will be carried out in accordance with the laws of Brazil, including the Marco Civil da Internet, Federal Law No. 12.965/2014 (“MCI”) and the General Data Protection Law, Federal Law No. 13.709/2018 (“LGPD”).

For the avoidance of doubt, matters not addressed in this section should be referred to the general Privacy Notice above.

2. INTERNATIONAL TRANSFERS

Some of the third parties who will receive your data are based outside Brazil. The countries receiving the data that we transfer may not offer adequate levels of personal data protection under applicable regulations. In such cases, Volt will take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and implement appropriate measures to ensure your personal information will remain protected in accordance with Volt Consumer Privacy Notice, such as standard contractual clauses or other mechanism provided for in the applicable law.

The services provided by Volt require the support of a technological infrastructure, such as servers and cloud services, which may be provided by third parties. Some of this infrastructure may be established outside Brazil.

3. YOUR LEGAL RIGHTS

You have the following data protection rights, which you can exercise at any time by contacting us by email (legal@volt.io) or postal address (Rua Dr. Virgílio de Carvalho Pinto, No. 306, apt. 121, Zip Code 05415-020, São Paulo).

  • The right to access your personal data and confirm the existence of processing. 
  • The right to correct, update or request anonymization, blocking or deletion of your personal information. 
  • The right to object to the processing of your personal information where it is based on our legitimate interests or in case of non-compliance with LGPD. 
  • The right to ask us, in some situations, to restrict the processing of your personal information or to request portability of your personal information. 
  • If we collect and process your personal information with your consent, you have the right to withdraw your consent at any time and request deletion of your personal data. Withdrawing your consent will not affect the lawfulness of any processing carried out prior to your withdrawal, nor will it affect processing of your personal information carried out on a legal basis other than consent. 
  • The right to request a review of decisions based solely on automated processing, which may affect your interests. 
  • The right to petition the National Data Protection Authority – ANPD about our collection and use of your personal information. 
  • The right to request portability of your personal data to another service provider.
  • The right to request information about with whom your personal data has been shared.

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. If you are aware of changes or inaccuracies in your information, you must inform us of such changes so that our records can be updated or corrected. 

To exercise your rights, you or your authorized legal representative may contact us using the contact details provided above. Once we receive your request, we may verify it by requesting sufficient information to confirm your identity.

Where we process your data for the purpose of entering or performing a contract with you, certain data is mandatory for that purpose. Any information provided to facilitate a payment you have requested is therefore mandatory. Where provision of data is mandatory, if relevant data is not provided, then we will not be able to fulfil your requests to register, make a purchase or otherwise engage with Volt. All other provision of your information is optional.