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60 Limassol Ave, CY-2014 Strovolos, Nicosia, Cyprus +357 22497700 [email protected]

Privacy Policy

This is the privacy policy of Fernworth Consulting Limited (Company Identification Number HE397889 registered in Republic of Cyprus). Fernworth Consulting Limited provides online payment gateway platform via the company Website (the “site”), our platform and its related services (collectively, the “Service(s)”). The services are operated by Fernworth Consulting Limited (the “company”, “we”, “us”, “Link4pay”) for users of the Service (“you”). The fundamental principles of Link4pay regarding privacy:

  • We don’t ask you for personal information unless necessary.
  • We don’t store personal information unless required for the on-going operation of one of our services.
  • We don’t share your personal information with anyone except to comply with the law.
  • We aim to make it as simple as possible for you to control what information you share with us.

Link4pay is bound by the General Data Protection Regulation (Regulation (EU) 2016/679) and the Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018). Below is our privacy policy which incorporates these principles. If you have questions about the privacy policy, please contact us at [email protected]. This privacy policy applies to the legal representatives and ultimate beneficial owners of all past, present and prospective Link4pay merchants (web shops/(online),POS Attended, POS Unattended, SoftPOS retailers) and other commercial contracting parties such as independent sales agents, anyone involved in any transaction with our platform, including non-Link4pay customers such as consumers/payees and anyone visiting our Site.

Non-Personally Identifying Information

We collect non-personal information − data in a form that does not permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect: We may collect information such as language, location, browser type, referral source, length of visit and the time zone where Link4pay services are used or accessed. We also may collect information regarding customer activities on our website, through our payment gateway and from our other products and services. This information is aggregated and used to provide more useful products to our customers by helping us understand which parts of our website, devices, and services are of most interest. Link4pay may also display this information publicly or provide it to others. However, Link4pay does not disclose personally identifying information. If you send us a support request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish the non-personally identifiable parts of it in order to help us clarify or respond to your request or to help us support other users. If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Personally Identifying Information

Link4pay also collects personally identifying information – data in a form that permits direct association with any specific individual. This type of information helps us provide better support for all of our users. We have two types of personally identifying information:

  • Information you provide us: This is the information you provide us when you use our services, make a transaction via our platform, and when you communicate with us through email, our site, portal, telephone or any other electronic means.
  • Information we get from your use of our product: We use various technologies to collect and store information when you use a Link4pay product or service, and this may include sending one or more cookies or anonymous identifiers to your device.
  • Such information may include you or your customer’s:
  • Name including first name and family name
  • Contact information (email, phone, billing address, shipping address etc.)
  • Card Payment Details (Card number, Card holder name, Card Expiry date, CVC details)
  • Bank and/or issuer details.
  • Transaction related information such as items purchased, the value, the time.
  • Information regarding the incoming requests to our platform such as user-agent, origin, IP address etc.
  • We strictly do not store any sensitive data relating to your health, ethnicity, religious or political beliefs.
  • Administration: When you open a merchant account with us we are legally obliged to collect personal data that verifies your identity and to assess whether we can accept your company as a customer. We need your contact information to be able to contact you.
  • Feedback: We may store the feedback you provide us about our services and share this within our team to make improvements to our services. We might also store notes on our interactions with us to customize products and services for you.
  • Data Security: We are duty bound to safeguard your personal data against threats such as fraud, laundering and other criminal usage of your data. We may use your information to protect you from fraudulent activities.
  • Reporting: From time to time, we may use your personal information to anticipate and resolve problems with any services provided to you and to comply with legal and/or regulatory requirements and other statutory requirements.
  • Please note that personal data provided by you is processed and stored only in the countries under European Economic Area (“EEA”). In certain circumstances your information may be processed outside of the EEA such as when we engage third parties based outside of the EEA to assist us with the services that you have requested from us. In such circumstances, we will take all steps necessary to ensure that any of your information is adequately protected and processed in accordance with this Privacy Policy. You consent to this transfer and processing of your information.

Protecting Personally Identifying Information

Link4pay discloses potentially personally-identifying and personally-identifying information to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Link4pay’s behalf, for example a bank requires your details, and (ii) that have agreed not to disclose it to others. Link4pay will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Link4pay takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information. All Link4pay employees engaged in the processing of Personal Data are informed of the confidential nature of the data, have received appropriate training on their responsibilities and have executed written confidentiality agreements.

Disclosure of Personal Information to Third Parties

If Link4pay, or substantially all its assets, were acquired, or in the event that Link4pay goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of Link4pay may continue to use your personal information as set forth in this policy. Other than to its employees, contractors and affiliated organizations, as described above, Link4pay discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when Link4pay believes in good faith that disclosure is reasonably necessary to protect the property or rights of Link4pay, third parties or the public at large.

Third-Party Privacy Policies

The data shared by Link4pay with third parties is strictly limited to the task we need the third party to perform. Link4pay services may contain links to third-party websites, products, and services. Our services may also use or offer products or services from third parties − for example, a third-party Link4pay app. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

Updating Your Personal Information

You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account. For other personal information, we make good faith efforts to provide you with access so you can request that we correct the data if it is inaccurate or delete the data if Link4pay is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made through [email protected]. We respect your rights as a customer and ensure we uphold all of these while processing of your personal data.

  • Right to Access Information: You have the right to ask us for all your personal data that we have stored.
  • Right to Rectification: If you find any of your personal data we have stored is incorrect, you have the right to ask us to rectify it. In case we have shared the relevant data with a third party, we will duly notify the third party.
  • Right to object to processing: You have the right to object to Link4pay using your data, including for legitimate business reasons. We will consider your objection and make available alternative methods for processing wherever possible without unduly burdening you.
  • Right to object to automated decisions: Our systems may sometimes make automated decisions based on your personal information with your consent if this is necessary to fulfil our contract with you. You have the right to object to such automated decisions and ask for an actual person to make the decision.
  • Right to Restrict Processing: You have the right to ask us to restrict using your personal data if you believe that we are processing your data illegally, or if you have objected to our legitimate use of your data for fulfilling our business requirements.
  • Right to Data Portability: You have the right to ask us to port your personal data to another service provider. This applies to the personal data we process with your consent, on the basis of a contract with you or by automated means.
  • Right to Erasure: You have the right to ask us to erase your data if we are no longer in need of the data or you withdraw your consent to our legitimate use for our business requirements. This is also applicable in scenarios where Link4pay is unlawfully processing your data and/or the European Union or a member state of the European Union requires Link4pay to erase your personal data.
  • Right to Complain: You have the right to complain to Link4pay if you feel your personal data is not being treated in the correct manner. You may also contact the data protection authority in your country.

Policy Changes

Link4pay may change its Privacy Policy from time to time to remain compliant with any changes in law or to reflect how we process your personal data. Link4pay encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of Link4pay products and services after any change in this Privacy Policy will constitute your acceptance of the change.