PRIVACY POLICY

Herein the following definitions will apply:

You refers to any User of the Covery Solution.

Your refers to that which belongs to the User.

We and Us refers to Maxpay.

Our refers to that which belongs to Maxpay or the Maxpay parties.

Maxpay means Maxpay Limited, a legal entity registered in Malta with registration number C 66555.

Maxpay parties refers to Maxpay affiliates, subsidiaries and its respective directors, employees, agents and shareholders.

The Site refers to the Covery Site (www.covery.ai) including all its content.

Client means an individual who purchases goods or services from User.

Covery Solution means software and a service powered by Maxpay provided to you to protect your online business from various types of fraud and reduces operational overhead.

Data means data and/or information submitted by you through the APIs and administrative platform to us, including your Clients’ personal data.


Covery is a risk platform powered by Maxpay Limited. Using Covery solution or other Maxpay's services, you are also subject to Maxpay's Privacy Policy and the agreement with Maxpay. The current Privacy Policy depicts your privacy rights in terms of gathering, use, storing, sharing, and protecting your personal data.


You agree to this Privacy Policy by registering, accessing, or using Covery solutions. If you do not agree, you should stop accessing this Site or Covery Solution immediately and refrain from further access and use of them.

ROLES AND RESPONSIBILITIES

You should be aware that by providing you with Covery Solution we act as a data processor and you act as a data controller in the meaning given by General Data Protection Regulation (GDPR). We process your Data only to provide you the Covery Solution and only on documented instructions from you. You shall warrant that you obtain prior consent from your Clients to collect, use and process their personal data by Maxpay.


You, as data controller, shall comply with all applicable data protection laws, rules and regulations. You should check if your privacy policy duly discloses your data practices, including using third-party service providers for detection and prevention of fraud. We, for our part, warrant to you that we comply with our obligations as a data processor under the applicable legislation and will assist you in ensuring compliance with your duties under GDPR. We will assists you by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of your obligation to respond to requests for exercising the data subject's rights. In cases when we collect personal data of merchant's officers, we act as data controller, therefore we are subject to controller's rights and obligations under applicable data protection laws.

INFORMATION WE COLLECT

Starting to use Covery Solution, you provide us with Data about your Clients. You can decide what types or format of Data you wish to send to Maxpay for analysis. You may sent your Client’s Data, such as email address, user login name, telephone numbers, IP address of the device used, the pages navigated by the Client, time of login/logout, items viewed, added to cart or purchased, the form of payment, partial credit card numbers, and order status.


Furthermore, in case you access your Covery account or otherwise use Covery solution, the following type of data might be gathered: your company name, phone number, e-mail, name of contact person. It is used to maintain permanent communication with you and to send you legal and information notices. You always have an option to unsubscribe from our mailing list by contacting us or using the relevant options in your Covery account. We do not collect any extra data but only that information that is necessary for the purpose of providing Covey Solution to you.

INFORMATION WE GATHER FROM YOUR COMPUTER OR MOBILE DEVICE

When you visit Covery Site or use Covery solution, we gather information provided by your computer, mobile device, or other viewports. This information includes data about pages you visit, your IP-address, device information, type of operating system, your location, web and mobile network data, and some other minor details. Note that we also gather information about your activities on the Site. The information mentioned above collected in order to safeguard you from scam, fraud, and misuse of any private data you might share. If your working station or mobile device has any malware, the system can notice that and take applicable measures.

COOKIES POLICY

When you visit Covery Site or use Covery solution, a small Cookie file might be placed on your computer or mobile device. We will analyze data from the Cookies and use it to improve quality of our services, track your activities with Covery Solution, keep your account safe. By clicking on or navigating the Site, you are agreeing to this Cookie Policy.


  • What the cookie is?

A cookie is a small text file stored in a computer’s web browser memory.

There are three main types of cookies:

Session cookies – they help you do not re-enter information and stay logged in each time you change web–pages. Session cookies are deleted automatically after you leave the Site or when you close your browser.

Persistent cookies – they help us to recognize you each time you return to the Maxpay Site and remember your preferences for viewing the site. Such cookies are stored on your computer until deleted by you or automatically after its expiration.

Third-party cookies - are the persistent cookies placed not by Maxpay which help to gather browsing activity across numerous websites and during several sessions. Such cookies are stored on your computer until deleted by you or automatically after its expiration.

You can find out more from https://www.aboutcookies.org/


  • How we use Cookies?

We use cookies for the following purposes:

Authentication. When you login in Covery Site or in Covery Platform, we use cookies to remember you so you don’t have login each time you left the main page and navigate throughout the Maxpay Site.

Fraud Prevention. With help of cookies we can obtain information about security of your computer and web browser used to access to Covery Site or Covery Platform and to detect harmful or illegal use of our Services.

Settings. We can use cookies to remember your settings of the Covery Solution so you don’t have to change it each time you log into Covery Site or in Covery Platform. For example, you can choose to remember payment details and associate it with your computer to make recurring payments or use language or font you prefer.

Improving Our Services. We use cookies to understand how we can make Covery Site or Covery Solution better. Cookies help us to know how people reach Covery Site, detect and gather reporting on bugs, improve functionality and speed of Covery Site and Covery Platform.

Marketing. From time to time we can use cookies to show you more relevant ads, e.g. to not show the same ads multiple times or recognize actions across multiple devices or browsers, etc. We reserve the right to use Google Analytics to understand how Covery Site and Covery Platform is used by its users. You can opt out of Google Analytics Advertising Features as described below.


  • What other technologies can we use?

There are other technologies used by us to track your activity on the Covery Site or Covery Platform.

Web beacons (web pixels) are small graphics helping to understand browsing activity, track conversion and optimize ads. These graphics file is downloading when you visit the Covery Site or Covery Platform.

Local Storage Objects (flash cookies) are files that can be stored on your browser and can be used to detect preferences, to record the history of usage, or remember settings of the Covery Site or Covery Platform. You can block or control flash cookies at any time by modify the settings of your browser.

Google Analytics. Google Analytics is third-party technology which allows to collect and analyze information about how you use the Covery Solution and web-sites and create relevant reports. For Google Analytics Advertising Features, you can opt-out through Google Ads Settings. Google also provides a Google Analytics opt-out plug-in for the web.

Mouseflow. Maxpay may use Mouseflow, a website analytics tool that may record your clicks, mouse movements, scrolling, form fills (keystrokes) in non-excluded fields, pages visited and content, time on site, browser, operating system, device type (desktop/tablet/phone), screen resolution, visitor type (first time/returning), referrer, anonymized IP address, location (city/country), language, and similar meta data. Mouseflow does not collect any personal information, nor does it track or collect any information outside your web browser.

If you'd like to opt-out, you can do so at https://mouseflow.com/opt-out.


  • How can you change Cookies settings

You can to delete and disable cookies using setting of your browser. You can find out more about how to manage cookies from the following links:

For Chrome browser: https://support.google.com/chrome/answer/95647?hl=en

For Explorer browser: https://support.microsoft.com/en-us/products/windows?os=windows-10

For Safari browser: https://support.apple.com/ru-ru/guide/mdm/mdmf7d5714d4/web

For Firefox browser: https://support.mozilla.org/en-US/kb/disable-third-party-cookies

For Opera browser: http://www.opera.com/help/tutorials/security/cookies/

Also you can use third-party tools, like browser plug-ins or applications allowing you to monitor, block or limit third-party cookies, web pixels and some javascript-based technologies.

PROTECTION AND STORAGE OF YOUR DATA

Under this Privacy Policy, the term “personal data” is used to depict information that can be linked to a specific person and thus be used to identify that very person. Information that has been made anonymous is not considered to be personal data.


Your Data is protected by the means of physical, technical, and administrative resources to lower the risks of loss, misusage, unauthorized entry, disclosure, or alteration by a third party. To keep your data safe we apply firewall and data encryption protection and physical authorization control system, just to name a few.


As Maxpay is PCI DSS 1 V3.2 certified, we maintain all required technology, methods and business processes to protect cardholder data, and also use such technology and methods as regards the security of other personal data we may receive.


We monitor our systems 24x7 and our staff is always ready to respond to your notifications and queries within a short time.

THE WAYS WE USE YOUR DATA

You should be aware that the processing of Data is necessary for the performance of a contract with Maxpay to which you are the party. The main goal of gathering your personal data is to carry out risk analysis to fight different types of fraud and to reduce your business risks.


Hence, the Data we collect might be used to:


Prevent you from becoming a subject to illegal activities and potential fraud;

Settle disputes, levy charges, and resolve occurring problems;

Improve the quality of Covery solution and Maxpay services;

Provide target-oriented services based on your experience with the company;

Being able to contact you in case of emergency via one of the means available;

Send marketing information (provided you can unsubscribe from our mailing list at any time);

Send legal and information notices.

Make sure information you provide is accurate, in case discrepancies occur.

Your Data is not used for any additional purposes not mentioned in this Privacy Policy or the contract with Maxpay.

HOW LONG WE RETAIN YOUR DATA

We may use your Data for as long as reasonably necessary for the limited purpose of providing fraud detection and prevention services, as determined by Maxpay in its reasonable discretion or for the purpose to comply of with technical and legal requirements related to the security, integrity and operation of Covery Solution. After the termination of the agreement between Maxpay and you, you may request deletion of your Data. We are able to delete your Data or information within ninety days.

PASSWORD SECURITY

You shall maintain the confidentiality of your password from Covery account. You are recommended to sign out of the Covery account when you have finished work with it. In any case responsibility for any loss of passwords and misuse of Covery account by third parties lay with you.

SHARING PERSONAL INFORMATION WITH THIRD PARTIES

We will not disclose your Data to any third party except Maxpay Parties which may use such information only for the limited purpose of providing services to you and who are obligated to keep the information confidential and comply with this Privacy Policy. We do not transfer your Data to any data processors, all Data we receive from you is processed by us. Insofar Covery Solution servers are situated in Europe we do not transfer your Data to any country that does not provide an adequate level of data protection.


Your Data may be disclosed to the third parties only to respond to valid legal process, including requests from law enforcement or other government agencies. In such case we will notify you as soon as possible.


If you transfer to us any personal data of your Clients you shall be obliged to obtain prior explicit consent for the collection, retention, use and processing of personal data by you and for transferring it to Maxpay.


We may share collected non-personal information with Maxpay parties or other third parties to help us prepare or share aggregate business and marketing reports.

ACCESSING OR CHANGING YOUR DATA

Note that you can review, update, edit your Data or request deletion of any personal data that has previously been provided to us at any time. Simply log in to your account and change profile settings at once or contact our support.


If requested by your Client we can:


Delete Client’s personal data;

Correct Client’s personal data that Maxpay retains;

Stop data processing if a previously given consent for processing was withdrawn

Provide all information we have about particular Client;

Temporary mark Client’s personal data as restricted so it will no longer be visible to the back office staff.

In case you obtain such request from your Client please contact us or use features available on Maxpay Site (maxpay.com).

However, Client’s personal information may be used further in order to track any unpaid fees, unresolved disputes, prevent from scam, or be used for any other activity if such required by law.

CONFIDENTIALITY

Your Data will be kept confidential in accordance with the agreement with Maxpay. We will use your Data solely as contemplated by this Privacy Policy and Terms of Use and will not disclose such information to any third parties except to our employees and/or agents, who are bound by obligations of confidentiality at least as strict as those contained in the agreement between you and Maxpay.

DATA BREACHES

We ensure you that we have all necessary technologies and methods to prevent, detect and investigate a personal data breach. In case of any data breach we will endeavor our best efforts to send a notification within 72 hours of becoming aware of the breach.

HOW MAY THIS PRIVACY POLICY BE CHANGED

We can make amendments to this Privacy Policy at any time by the means of publishing a revised edition on the Site. You will be notified of any substantial changes. The revised version will be in effect immediately and be noted by updated date to the end of this Privacy Policy. You should revisit the Site to stay aware of any changes. You are entitled to terminate the agreement with Maxpay if you do not agree on any changes. By continuing using Covery Solution, you accept the changes.

Please feel free to contact us to ask any questions or notify us of a data breach.


Our contacts:

Question regarding the personal data protection may be addressed to our Data Protection Officer to the following e-mail address dpo@maxpay.com

Last modified: May 22, 2018