Antom Privacy Policy for Merchant Services

2024-04-25 05:34

Last updated: 2024-04-25

We provide payment processing, reconciliation and settlement, and other related services to our customers globally (“Antom Services”). This Privacy Notice describes how we collect, use, and share personal information in relation to the Antom Services.

This Privacy Notice applies to:

visitors to our websites (including https://www.antom.com) or any other person who contacts us over the telephone, email or other means (“Visitors”);
customers who register for and/or use Antom Services (“Customers”). This may include merchants, platforms, and sub-merchants (for instance if you have an account on a platform);
consumers who do business with, or otherwise engage in a transaction with a Customer, such as those buying goods and services from a Customer using Antom Services for payment processing (“End Users”); and
personnel, officers, and connected persons of our Customers and other partners (“Representatives”) where their personal information is provided to us in connection with the Antom Services.

Unless otherwise indicated or the context requires otherwise, reference to “you” or “your” are intended to refer to a Visitor, Customer, End User and/or Representative, and reference to “Antom”, “we”, “us” or “our” in this Privacy Notice refer to Alipay Singapore E-Commerce Private Limited, Alipay (Europe) Limited S.A., AUS Merchant Services, Inc., Alipay (UK) Limited, and other affiliates involved in providing the Antom Services to you (each an “Affiliate” and collectively referred to as the “Group”).

1. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We collect and use personal information about you, including when you interact with us, register for an account, contact us directly with respect to any queries or otherwise communicate with us, use the Antom Services to make purchases or otherwise conduct financial transactions, or otherwise visit or use our Antom Services.

We may collect the following personal information about you:

your basic personal details, including first and last name, date of birth, and copies of your government ID documents (e.g., passport, driver’s licence or social security number);
contact information, including your address, phone number, email, or other information that permits us to contact you;
account information, such as payment methods and details of the payment card used to complete a transaction with a merchant;
in relation to Representatives:

copies of government ID documents and role and relationship with the relevant Customer or partner;
company registration details, such as the basic personal details of the ultimate beneficiaries and account authentication details to complete “know your business” or “know your client” checks as required by local law;
financial information and tax identification information;

transaction details, such as the merchants you deal with, the amounts paid, details of the products and/or services purchased, and information related to requests for chargebacks and/or refunds;
details of any marketing preferences you have given us (such as requests to receive or not receive certain types of marketing communications);
copies of communications with or about you; and
the following usage, device, and technical information:

information about the device you use to interact with us and our services (including IP address, geographical location, device type and model, screen resolution, app version, device language, device identification codes and other features/data that can be used to identify a device), and
information from your visits to our websites or mobile applications, and your interactions with our emails or other communications. This information includes browser history, product engagement, length of visit/usage, page views and any search term you use, IP address or other unique identifiers, browser/platform type and version, internet service provider, operating system, referral source/exit pages, device operations, session information, device ID, user agent, device logs in the event of a crash or error report, and unique identifiers saved in cookies and information associated with a cookie which is necessary to provide the services you have requested or which helps us measure and improve our sites.

As noted above, we collect personal information which may be considered sensitive in certain jurisdictions. Specifically, if we collect your passport, your payment card information, or your financial information and tax identification information, you may have additional rights and protections with regard to such sensitive personal information under certain data protection laws.

We will indicate whether the provision of personal information is mandatory or optional. If you do not provide mandatory personal information to us, you may not be able to use the Antom Services.

2. HOW WE OBTAIN YOUR PERSONAL INFORMATION

We collect the above personal information (including sensitive personal information, if any) from various sources, either directly from you or indirectly, as set out below.

We collect personal information directly from you when you provide it to us in connection with the Antom Services. For example, we collect your personal information when you enquire about or register to use any of the Antom Services, sign an agreement with us, provide your personal information during the merchant onboarding process, log into your account to use the Antom Services on our sites, or when you communicate with us via e-mail, phone, SMS, or any other electronic means.

We also receive personal information about you from the following sources:

Customers and other third parties who support the ability to make payments and conduct transactions through Antom Services or otherwise;
Affiliates;
suppliers providing services on our behalf;
banks, card associations, payment networks, acquiring institutions, and other financial institutions that we cooperate with to provide you with the Antom Services;
third parties for fraud monitoring and prevention purposes, or other purposes required by law;
in relation to Representatives, from the relevant Customer or partner; and
publicly available sources.

We may combine information that we have about you from various sources, including the information you have provided to us.

Please refer to the section How We Use Your Personal Information below for more details.

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information (including sensitive personal information, if any) to provide you with Antom Services. More specifically, we may use your personal information for the following purposes:

for the exercise of rights and performance of obligations under, and managing compliance with, our agreements and related Antom documentation;
processing, maintaining and managing your registration with our services;
providing you with Antom Services and related services, including enabling and conducting transactions, customizing your user experience, enabling the receipt of balance top-ups, financing proceeds and third-party payments, facilitating the settlement of payment for goods and services and providing other fund settlement services, handling foreign exchange conversions, chargebacks, and sending notices about transactions;
to respond to your queries, feedback, claims or disputes (including resolving payment disputes) or otherwise provide customer support and services;
contacting you in relation to our provision of Antom Services, contacting you in connection with any communication preferences or requests you have expressed, asking you for feedback about Antom Services or other related products and services, collecting feedback from you and your staff about our products and services and using such feedback to improve our business and/or customize products and services, and contact you for legal purposes;
to operate marketing and advertising activities (including trade shows and promotional events), and send you advertising or other information about our products and services;
for security, authentication and risk control purposes, including to verify your identity, verify your eligibility as a user of Antom Services, manage anti-money laundering and fraud risk, to perform creditworthiness and solvency checks, assessing, detecting, investigating, preventing or remediating fraud, data breaches or other potentially prohibited or illegal activities and violations of our agreements and policies, industry standards, guidelines, laws and regulations, and otherwise protecting the integrity and maintaining the security of our services, products and platforms, to protect our rights or property and those of others and to prevent any harm or financial loss to us or others;
in relation to Representatives, (i) to carry out “know your client” checks and for onboarding and due diligence purposes; (ii) to manage and develop the relationship with Customers or partners; and (iii) to communicate with Customers or partners;
making disclosures as may be required by any rules, law or regulation, regulatory authorities, government officials, card association or other payment network. Such disclosures may also be made pursuant to any subpoena, court order or other legal process or contractual or commercial requirement applicable to us or any Affiliates (including “know your customer”, anti-money laundering, counter-terrorist financing reporting, tax requirements or other commercial disputes);
improving and optimizing the Antom Services, conducting research, statistical analysis, analytics, business planning and business intelligence purposes in order to understand how users like you perceive our products and services, industry trends, usage patterns and other factors that may affect our business;
to manage our business, including billing, invoicing, account management, reconciliation, collection, audit purposes and internal reporting;
for the establishment, exercise or defense of legal claims or potential claims on behalf of ourselves or our Affiliates, for the purposes of legal proceedings, for compliance, regulatory and investigative purposes;
for any proposed or actual merger, acquisition, corporate reorganization, financing, joint venture, assignment, transfer, disposition or similar transaction, including the sale of business, assets or stock;
to comply with law, regulation, codes of conduct and other good practice and conduct requirements, and any requirements or rules imposed by payment schemes; and
in any other ways for which we provide notice at the time of collection.

4. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We share your personal information (including sensitive personal information, if any) for the purposes indicated under the section How We Use Your Personal Information above, with the following categories of recipients:

our Affiliates;
Customers that provide you with products, services and other offerings on or through Antom Services;
any agent, contractor, vendor, or service provider that we work with in providing Antom Services. We set out a list of such agents, contractors, vendors, and service providers here;
service providers elected by you;
third parties where you have instructed us to share information with them;
banks, card associations, payment networks or acquiring institutions, and other financial institutions involved in processing of payments and conducting transactions through Antom Services;
law enforcement agencies, insurers, government and regulatory or supervisory authorities or any other organizations to which we, or any of our Affiliates or service providers, are under an obligation to make disclosure under the requirements of any applicable law, regulation, code of conduct or good practice or conduct requirement or commercial arrangement;
parties relevant to litigation proceedings and the assessment of claims or disputes, including courts;
individuals and entities involved in any merger, acquisition, corporate reorganization, financing, or similar transaction with us, including in the event of the sale of all or part of our assets; and
our own and others’ professional advisors (e.g., lawyers, accountants, auditors, and trustees).

See the section How Do We Store And Protect Your Personal Information? for information on how long we retain your personal information and how we try to keep your personal information secure when storing it or sharing it with others.

5. HOW DO WE STORE AND PROTECT YOUR PERSONAL INFORMATION?

We will keep your personal information (including sensitive personal information, if any) in accordance with our policies and for as long as it is necessary to provide you with the Antom Services or other purposes as set out in this Privacy Notice. In addition, we may retain your personal information (or sensitive personal information, if any) for a longer period (including after you are no longer a user of our services) if it is necessary to comply with laws and regulations applicable to us. The criteria we use to determine the appropriate retention periods are:

regulatory requirements that we are subject to;
whether a legal claim could be brought against us;
necessity of information to provide the Antom Services;
the type, nature, and sensitivity of your personal information being processed; and
the legal basis for processing – e.g., consent.

We use a variety of security measures and technologies designed to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction, consistent with applicable data protection and privacy laws and regulations.

6. WHAT IS OUR LEGAL BASIS FOR COLLECTING AND USING YOUR PERSONAL INFORMATION?

We collect and use your personal information on one or more legal bases set out below (and where applicable, under any other legal bases permitted under the relevant data protection legislation).

For the performance of any contracts to which you are a party.
To comply with legal and regulatory obligations.
With your consent – for example when you give consent to our use of cookies in order to measure and improve our sites.
For legitimate interests:

to operate, market and improve our business and minimise any disruption to the Antom Services that we may offer to you;
to ensure the security of the Antom Services and to protect us, our staff, users and others from fraud or other criminal or similar conduct;
to comply with codes of conduct, codes of practice and similar good conduct principles which do not have the force of law in the countries in which we operate, but are prudent for the Group to apply;
to send you service-related communications and marketing/promotional communications, to make our communications with you more relevant and personalised to you, and to make your experience of our products and services efficient and effective;
to transfer your personal information internationally (including to Singapore, the European Economic Area, the United States, Malaysia and China) in order to accommodate our technical infrastructure and as part of our business structure, including as a result of laws and regulations applicable to us and other Affiliates and legal claims or proceedings that involve us or other Affiliates; and
for other purposes including those set out in section 3.

However, in cases in which we wish to use your personal information for our legitimate interests, we carefully consider the position and do not proceed if we think your interests or fundamental rights and freedoms relating to your personal information would be prejudiced.

7. INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION

We are a global business and your information may be processed outside of the country where you live. These other countries might have data protection regulations that are different from those in your country. Regardless of where your information is processed, we take measures to comply with applicable data protection laws related to such transfer.

If you are located in the EEA, the UK or Switzerland, any transfers of your data to third countries will be in accordance with standard data protection clauses approved by the European Commission or approved under UK or Swiss data protection laws (often called “SCCs”), or other lawful methods available to us under applicable law. You can find information about the SCCs here.

8. YOUR CHOICES AND PRIVACY RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

In accordance with applicable data protection and privacy laws and regulations, you may be entitled to:

ask us about the processing of your personal information and access it, including by asking us to provide you with a copy of your personal information;
request the correction and/or updating of your personal information;
request the deletion of your personal information;
request the restriction of the processing of your personal information, or object to that processing;
withdraw your consent to the processing of your personal information (where we process your personal information based on your consent);
opt-out of email marketing and certain other communications. You may manage your receipt of marketing communications by clicking on the "Unsubscribe" link located on the bottom of any Antom marketing email and/or following the instructions found on any page to which the link may take you. Please note that you cannot opt out of receiving administrative, support, or transactional emails;
request receipt or transmission to another organisation, in a machine-readable form, of the personal information that you have provided to us where we are using your personal information based on consent or performance of a contract; and
complain to the relevant supervisory authority.

If you are a User located in the United States, you may also be entitled to:

Access/Right to Know: You may ask for: (i) a portable copy of the specific pieces of your personal information that we have collected; (ii) a list of categories of personal information (and sensitive personal information) we have collected about you; (iii) a list of categories of sources from which such information was collected; (iv) a list of categories of information that we sold or disclosed for a business purpose about you; (v) a list of categories of third parties to whom the information was sold or disclosed for a business purpose; and/or (vi) the business or commercial purpose for collecting and selling your information.
Deletion: You may request that we delete the personal information we have collected about you, subject to certain exceptions.
Do Not Sell or Share My Personal Information for Behavioral Advertising: We do not “sell” your personal information to third parties for monetary consideration. You may opt out of analytics cookies as explained below.
Correct or Update Your Personal Information: You have the right to request that we correct, update, or modify the personal information we maintain about you.
Limit the Use and Sharing of Your Sensitive Personal Information: In relation to any sensitive personal information identified in section 1 above, you can request that we limit our use and sharing of such information to those uses which are necessary to perform the Antom Services or as otherwise allowed by relevant data protection laws.

Please note that these rights are not absolute and are subject to a number of exceptions and qualifications that mean they may not always apply.

Submitting Privacy Rights Requests: If you would like to exercise your privacy rights, contact us using the details set out in the Contact Us section below. If you would like to withdraw consent to our use of analytics cookies, our cookie notice explains how to do this.

Where you are given the option to share your personal information with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your personal information with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described (see section How We Use Your Personal Information) or that you are unable to make use of the services and products offered by us. After you have chosen to withdraw your consent, we may be able to continue to process your personal information to the extent required or otherwise permitted by applicable data protection and privacy laws or regulations.

Non-Discrimination: If you exercise any of the above privacy rights, we will continue to treat you fairly and without discrimination. If you exercise your rights under this Privacy Notice, you will not be denied or charged different prices or rates for the Antom Services, or provided a different level or quality of goods or services than others.

Verification of Your Identity: Depending on the nature of your request, we will ask you for identifying information and attempt to match it to information that we maintain about you in order to verify your identity. Not all of the above request types will be subject to verification. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial.

Authorized Agents: You may designate an agent to submit requests on your behalf. When submitting a request through the methods described above, the agent must identify itself as your authorized agent. Depending on the type of request being submitted, we may request additional verification to confirm you have authorized the agent to act on your behalf.

9. ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES

For purposes of the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), please also note the following specific information about how we collect, use, and share California residents’ personal information:

Depending on our interactions with you, we may collect, use, and disclose for our business and commercial purposes the following categories of personal information set forth in the CCPA and CPRA: identifiers; payment and customer records information; commercial information; internet or other electronic network activity information; and sensitive personal information. See section 1 above for more details.
We collect and use the above categories of personal information for the business and commercial purposes described in section 3 above.
We collect these categories of personal information from the sources described in section 2 above.
We may disclose each of these categories of personal information to the categories of third parties as described in section 4 above.

10. HOW DO WE PROCESS PERSONAL INFORMATION ABOUT CHILDREN?

Our services are not directed towards children under 18 years old, nor does Antom knowingly collect information from children under 18. If you are under 18, please do not use the Antom Services or submit any personal information to us.

If you, acting as a guardian of a child, have relevant questions in respect of a child’s personal information, please contact us using the details set out in the Contact Us section below.

11. THIRD PARTY SERVICES AND SITES

We may provide links to third party websites and services (including other online merchant sites) for your convenience and information. These services and websites may operate independently from us. Linked services and websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked services and websites. To the extent any linked websites and services you visit are not owned or controlled by us, we are not responsible for (i) these websites’ or services’ content, (ii) any use of these services or websites by you, or (iii) the privacy practices of these services or websites.

12. CHANGES TO THIS PRIVACY NOTICE

We may change, amend or revise this Privacy Notice from time to time. We will notify you of any substantive or material change in this Privacy Notice through a combination of updating this webpage, sending push notifications, e-mails or letters, by phone or by publishing announcements on our websites. You can review this Privacy Notice any time at the homepage of our websites.

Once posted on our website, the new Privacy Notice will become immediately effective unless stated otherwise.

13. CONTACT US

If you have questions or requests about the privacy of your personal information, please contact us by email via Privacy-OpenPlatform@alipay.com or at the following business address if you are in:

the European Economic Area or Switzerland: Alipay (Europe) Limited S.A., Privacy Office, 11-13, 9, rue du Laboratoire, L-1911 Luxembourg.
the United States: AUS Merchant Services, Inc., Privacy Office, 525 Almanor Avenue, Suite 100, Sunnyvale, CA 94085.

As required under applicable law, please note that we may take steps to ask you to provide further information to verify your identity before granting you access to information or acting on your request to exercise your rights.