Privacy Policy
Effective as of November 2023

1. Introduction
At Zavo Ltd and its affiliates (“we”, “us”, “our”), your privacy is paramount. This Privacy Policy (“Policy”) describes how we collect, use, share, and protect your personal information when you use the Zavo App (the “App”), create a Zavo Account, and engage with our services, including the Zavo Rewards Program. This Policy also applies to our website at https://zavopay.com/ (the “Site”).

Our services allow Merchant clients to process payments for goods and services. We also handle personal information from End Users when they make transactions through a Zavo Terminal. As the data controller, we are responsible for managing your personal information in compliance with data protection laws, and you have specific rights regarding your data.

Definitions:

• Merchant User: A business or prospective customer using Zavo's payment terminals and associated app.

• End User: An individual who makes purchases using a Zavo Terminal through a Merchant User.

• Zavo Card: A virtual payment card available to Merchant Users for transactions and earning rewards.

• Zavo Rewards Program: A rewards scheme offering benefits, such as reduced processing fees, to Zavo Card holders and Merchant Users.

• Zavo Terminal: A device or payment gateway used to process payments through Zavo.

Our services are intended for individuals aged 18 and over. We do not knowingly collect information from minors.

2. Information We Collect and Use

For Merchant Users:

• Account Creation: When you download the App and set up an Account, we collect your contact information (e.g., name, address, phone number, email) and details needed for identity verification. This includes business ownership information and identification documents to meet regulatory requirements.

• Transaction Processing: We collect transaction data to process payments, which may include payment amount, card details, and device information. This data helps us ensure accurate payment processing and compliance with our obligations.

• Zavo Card Enrollment: When you sign up for a Zavo Card, we process your personal data, including Account and Transaction Data, to manage your card activities and rewards.

• Rewards Program: We track your purchase activity and rewards eligibility to provide benefits and offers through the Zavo Rewards Program.

• Service Administration: We use your contact details to support you, resolve issues, and communicate about our services.

For End Users:

• Payment Transactions: When you use a Zavo Terminal for payments, we collect transaction data, including payment details and location information, which may identify you.

3. Legal Bases for Processing

We process your information based on the following legal grounds:

• Compliance with Legal Obligations: To meet regulatory requirements, such as anti-money laundering and fraud prevention.

• Contractual Necessity: To fulfill our contractual obligations with you, including processing payments and managing accounts.

• Legitimate Interests: For business purposes such as improving services, marketing, fraud prevention, and customer support.

• Consent: When required, such as for certain marketing activities or non-essential cookies.

4. Sharing Information with Third Parties

• Payment Processors: We share information with payment processors, including Stripe, for transaction processing and fraud detection. For details, see Stripe's Privacy Policy.

• Tokenization Providers: We use tokenization services like TrueLayer to secure financial data and ensure compliance.

• Service Providers: We may share information with cloud storage providers, analytics services, and legal advisors.

• Regulatory Bodies: We disclose information as required by law or for fraud prevention and legal enforcement.

5. Cookies

We use cookies to enhance your experience on our Site. For more details, please refer to our Cookie Policy.

6. Data Security

We implement robust security measures to protect your information from unauthorized access, loss, or misuse. While we strive to secure your data, we cannot guarantee complete security due to the inherent risks of internet transmission.

7. International Data Transfers

We may transfer your personal information outside the UK and implement measures to ensure it is protected, such as using approved contractual clauses or relying on frameworks like the UK-US Data Bridge.

8. Data Retention

We retain your information only as long as necessary for the purposes for which it was collected, including legal and compliance requirements. Personal information may be retained for up to 7 years, and anonymized data may be kept for analytical purposes.

9. Your Rights

You have rights under data protection laws, including:

• Accessing and obtaining copies of your personal data

• Requesting corrections or deletions

• Restricting or objecting to processing

• Withdrawing consent where applicable

To exercise these rights, please contact us as outlined below.

10. Complaints

If you have concerns about our data practices, please contact our Data Protection Manager at privacy@zavopay.com. You also have the right to file a complaint with the Information Commissioner’s Office.

11. Policy Updates

We may update this Policy periodically. Any changes will be posted on our Site. We recommend reviewing this Policy regularly.

12. Contact Us

For questions or to exercise your rights, contact us at:

Email: privacy@zavopay.com
Address: Zavo Ltd, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ