Privacy Policy

Protecting your privacy and personal data is a priority for Paynote.

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This Privacy Policy explains how Paynote Sp. z o.o. (collectively referred to as “Paynote”, “we”, “us”, or “our”) collect, use, process, disclose, and protect your Personal Data when you use our services, platform, or website (collectively, the “Services”). For the purposes of this Privacy Policy, references to Paynote include both Paynote LLC (United States) and Paynote Sp. z o. o. (Poland). Paynote Sp. z o. o. is a wholly owned subsidiary of Paynote LLC.

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This Privacy Policy applies to all users of the Paynote platform and related services.

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1. Roles and Legal Basis for Processing

Depending on the context in which your Personal Data is collected, Paynote may act as either:

• Data Processor — when processing Personal Data on behalf of your employer, company, or contracting party acting as the Data Controller, or

• Data Controller — when you provide Personal Data directly to us, such as when registering an account or interacting with our services.

When Paynote processes Personal Data, it does so under one or more of the following lawful bases:

• Performance of a contract

• Compliance with legal obligations

• Legitimate business interests, provided such interests do not override your rights and freedoms

• Consent, where required under applicable law

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2. Purpose of Data Processing

Paynote processes Personal Data to:

• Provide and operate the Paynote platform and related services

• Verify user identity and comply with financial regulations

• Facilitate the processing payments and financial transactions through providers

• Detect, prevent, and investigate fraud or illegal activities

• Communicate with users regarding services or support

• Comply with legal, regulatory, and compliance obligations

• Improve system functionality, security, and performance

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3. Categories of Personal Data We Collect

We do not collect Personal Data unless it is provided by you, your employer, or through your use of the Services.

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The categories of Personal Data we may process include:

Identification Data

• Name

• Company name

• Government identification information (when required for verification)

Contact Data

• Corporate email address

• Corporate mailing address

• Business contact details

Financial Data

• Payment transaction details

• Credit card information

• Bank account or IBAN details

Technical and Usage Data

• IP address

• Device identifiers

• Country or approximate location

• Online identifiers

• Usage logs and system interaction data

This information may be collected when you:

• Register an account

• Use the Paynote platform

• Contact us via email or support channels

• Submit payment information

• Interact with our website or applications

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4. Cookies and Automated Technologies

Paynote may collect certain information automatically through cookies and similar tracking technologies.

‍Cookies are used to:

• Ensure proper functioning of the platform

• Maintain session security

• Improve user experience

• Analyze service usage

Users may manage cookie preferences through the Cookie Management Tool available on our website. Cookies that are not strictly necessary for the operation of the platform may be disabled.

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5. Sharing of Personal Data

Paynote does not sell, rent, or lease Personal Data to third parties.

We only share Personal Data with trusted service providers that assist us in delivering our services.

These providers are contractually obligated to:

• Process data only according to our instructions

• Maintain appropriate security safeguards

• Protect the confidentiality of Personal Data

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6. International Data Transfers

Because Paynote operates globally, Personal Data may be transferred to and processed in countries outside the United States or United Kingdom.

When such transfers occur, Paynote ensures appropriate safeguards are implemented, including:

• Standard Contractual Clauses (SCCs)

• Adequacy decisions by the European Commission

• Equivalent contractual protections ensuring data security and confidentiality

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‍7. Legal Disclosures

Paynote may disclose Personal Data if required to do so by law or when such disclosure is necessary to:

• Comply with legal obligations or regulatory requirements

• Respond to lawful requests from government authorities

• Protect the rights, safety, or property of Paynote, its users, or the public

• Detect, prevent, or investigate fraud or illegal activity

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8. Your Privacy Rights (GDPR & CCPA)

Depending on your location, you may have rights under data protection laws including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

These rights may include:

Right of Access - Request confirmation of whether we process your Personal Data and obtain a copy of that data.

Right to Rectification - Request correction of inaccurate or incomplete Personal Data.

Right to Deletion - Request deletion of your Personal Data where permitted by law.

Right to Restrict Processing - Request limitations on how we process your Personal Data in certain circumstances.

Right to Data Portability - Request a copy of your Personal Data in a structured, machine-readable format.

Right to Object - Object to processing based on legitimate interests.

Right to Withdraw Consent - Where processing is based on consent, you may withdraw that consent at any time.

Right to Non‑Discrimination (CCPA) - Paynote will not discriminate against you for exercising your privacy rights.

Right to Know (CCPA) - California residents have the right to request disclosure of:

• Categories of Personal Data collected

• Sources of Personal Data

• Business purposes for processing

• Categories of third parties receiving data

Right to Opt‑Out of Sale (CCPA)

Paynote does not sell Personal Data.

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9. Exercising Your Rights

To submit a verifiable privacy request, contact:

Email: compliance@paynote.com

We may request additional information to verify your identity before fulfilling your request.

Requests will be handled in accordance with applicable legal requirements.

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10. Data Retention

Paynote retains Personal Data only for as long as necessary to:

• Provide services

• Fulfill contractual obligations

• Comply with regulatory or legal requirements

• Resolve disputes

• Enforce agreements

Certain financial and compliance records may be retained longer where required by law.

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‍11. Children’s Privacy

Paynote services are not intended for individuals under the age of 18.

We do not knowingly collect Personal Data from minors. If we become aware that Personal Data belonging to a minor has been collected, we will take steps to delete the information promptly.

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12. Security of Personal Data

Paynote implements appropriate technical and organizational security measures designed to protect Personal Data against:

• Unauthorized access

• Accidental loss

• Disclosure

• Alteration

• Destruction

While we strive to protect Personal Data, no system can guarantee absolute security.

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13. Changes to this Privacy Policy

Paynote reserves the right to update this Privacy Policy from time to time.

When updates occur, the revised policy will be posted on our website with an updated effective date.

Your continued use of the Services after such updates constitutes acceptance of the revised Privacy Policy.

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14. Contact Information

For privacy inquiries or requests, please contact:

Paynote 

Email: support@paynote.com

Data Protection Officer: compliance@paynote.com