Privacy Policy
Obligations related to personal data processing
Last updated: March 2025
Silkpay takes personal data protection very seriously and takes all necessary measures to ensure compliance with European Regulation 2016/679 of April 27, 2016 (hereinafter referred to as "General Data Protection Regulation" or "GDPR") and any other relevant provisions. Applicable personal data (hereinafter collectively referred to as the "Applicable Regulations").
This Data Notice on Silkpay's Personal Data Processing as a Processing Responsible (the "Notice") is intended to inform you of the method in which Silkpay handles your personal data and the commitments made by Silkpay to ensure that your personal data is properly handled.
1. What is the scope of this leaflet?
This notice applies to Silkpay S.A.S. All personal data processing performed at 95 avenue Président Wilson CS 5003-93108 Montreuil Cedex, contact@silkpay.fr (hereinafter referred to as "Silkpay" or "We") as data controllers within the meaning of applicable statutes and in relation to:
- Merchants who use or wish to use Silkpay services to accept payment solutions or, where applicable, their employees, legal representatives or actual beneficiaries (hereinafter referred to as "Merchants");
- Consumers whose personal data (including pseudonym data) may be processed when using our services (hereinafter referred to as "End users");
- Banking Partners (Payment Service Providers) or other Partners or, where applicable, their Employees (hereinafter referred to as "Partners");
- Applicants who wish to spontaneously apply for or respond to Silkpay vacancies through the email address on our website (hereinafter referred to as "Applicants");
- Any individual person in contact with Silkpay, if you have any enquiries, including through our website https://www.silkpay.eu/ by contacting any user of the form or our website.
Please note that, in addition to processing by Silkpay as a data Processor, depending on the purpose of the processing, Silkpay may be required to process the personal data of individual people on behalf of its customers/partners (including banking partners) as processors within the meaning of applicable regulations. These treatments are outside the scope of this Notice.
2. What data are collected?
2.1. The information we're dealing with
Depending on the type of service we provide you and/or our relationship with you, we may collect different
types of personal data about you, including:
About merchants and partners:
- Information about your identity or the identity of your legal representative or direct beneficiary (last name, first name);
- Contact information needed to contact you, especially your email address and business phone number;
- Any other data required to perform/use our services, including identification and authentication data, especially when using your backoffice (technical logs, computer tracing, security information).
About end users:
- Transaction data, including your name, mobile phone number and wallet identifier, including pseudonym form. However, we may also be required to process the data as processors on behalf of our banking or merchant partners (in this case, these partners are responsible for data processing).
About any individual person who contacts us, including through our online contact list:
- Your identity and contact information (last name, first name, email address);
- Any information you voluntarily provide through the contact form provided on our website https://www.silkpay.eu/;
- Any information you may provide to us when contacting us by phone or requesting access to our products and services.
About visitors to our website and/or mobile applications:
- Your IP address and other data collected through a cookie or other tracker: We invite you to check out our cookie notifications at www.silkpay.eu/cookies for more information.
About candidates:
- Your identity and contact information (last name, first name, email address and phone number);
- Any information you provide us when you send your application via email, in particular your resume and cover letter.
When your personal data is sent to us in a form, whether the information you must fill in is mandatory or optional will be indicated by an * at the time of collection. Silkpay believes that any unanswered or irregular reply may cause Silkpay to refuse to consider your request.
You promise to provide Silkpay with up-to-date, accurate and complete personal information about you.
2.2. Specific information related to the legal obligations of the banking and financial sectors
We may also be required to collect certain specific information (e.g.: ID cards, transaction data) relating to merchants or end users, our legal obligations under banking regulations in terms of anti-money laundering and combating the financing of terrorism (hereinafter referred to as "LCB-FT") and knowing customers (hereinafter referred to as "KYC"), especially when we act as banking regulators. Payment service providers within the meaning of banking regulations.
When we act as an agent (payment service provider) on behalf of our banking partners, we may need to collect this information as a subcontractor, on behalf of our banking partners and according to their instructions, in which case these partners are responsible for processing this information according to applicable regulations.
2.3. Cookies
For cookies and other trackers stored on your device when you browse our Web site or mobile app, we invite you to check out our cookie information notification, which can be found at www.silkpay.eu/cookies.
3. What do we use your personal data for? What is the legal basis for our use of your personal data?
Silkpay is committed to collecting and handling your personal data in a fair and legal manner. Silkpay's processing has a clear, explicit, and legitimate purpose.
Therefore, your personal data can be used for the following purposes:
- Perform our services and manage our contractual relationship.
In this case, the legal basis for processing is the execution of the contract (or pre-contract measure) between Silkpay and you.
- Answer your questions or requests and handle any complaints you may have: Silkpay can use the
collected data to answer your queries about Silkpay services, such as.
=> In this case, the legal basis for processing is either the performance of the contract, if the request is related to the contractual relationship between Silkpay and you, or the legitimate interests of Silkpay, especially its interests in satisfying your inquiries and ensuring high-quality customer service.
- Carry out statistical analysis, develop our site, optimize your browsing experience and personalize your experience: For this purpose, cookies or other trackers may be placed on our site-for more information, you can refer to the cookie notice at www.silkpay.eu/cookies.
=> In this regard, the legal basis for processing is Silkpay's legitimate interests, especially its interest in improving its website and services, as well as providing you with appropriate content and optimal navigation.
If you contact us, please follow up your application.
=> In this case, the legal basis for compensation is Silkpay's legitimate interest, in particular its interest in responding to your application and finding appropriate profiles for existing positions within Silkpay.
- Provide you with marketing and advertising (BtoB) information: Silkpay can send business documents, including via email, to merchants and potential partners in order to provide them with information about their activities and services (unless the merchant/partner objects according to applicable regulations).
=> In this regard, processing is based on Silkpay's legitimate interests, in particular its interest in promoting its services, offering personalized offers, better understanding of the needs of partners and merchants, and providing them with appropriate services to build loyalty.
- Investigate any violation or suspected violation of our rights or property
In this regard, the treatment is based on Silkpay's legitimate interests, especially defending its interests.
Respond to and comply with any legal requirements and our obligations under LCB-FT and KYC
regulations (only when Silkpay is the controller of these processes, and in particular when Silkpay is a payment service provider within the meaning of banking regulations) or any other legal or regulatory obligations.
=> In this case, the treatment is based on compliance with Silkpay's legal obligations and/or Silkpay's legitimate interests.
- Respect your choice when we require your prior consent. As part of certain specific processing activities, we will provide you with specific information related to these processes and seek your prior consent as required by applicable regulations.
=> In this case, treatment is based on your consent.
4. How long do we keep your personal data?
Silkpay keeps your personal data on an activity basis for no longer than is necessary for the purposes for which it is collected and processed.
However, Silkpay may then keep your personal data in file form to comply with its legal and regulatory obligations, or take into account the applicable limitation period, so as to enforce, exercise or defend rights in court (for example, in commercial cases, the statutory limitation is in principle five years). For example, in the most common personal data processing, we use the following retention period:
- Personal data related to merchants and partners shall not be kept for longer than is strictly necessary to manage the contractual relationship. Certain data preserved to prove a right, a contract or under a legal obligation will then be archived in accordance with regulations for the time necessary for the purpose of preserving such data. For example, according to the applicable regulations, even if we no longer have a business relationship with the data subject, we will archive all invoice data required for accounting for 10 years.
In addition, we keep merchant and partner data for three years, from the end of the business relationship (for example, the last contact of the customer at the end of the service contract), for commercial exploration purposes. Then, we can archive the data within the applicable legal limitation period;
- We maintain data relating to any non-Customer/Partner Prospect (for marketing purposes) for 3 years, from the last contact with the Prospect (or until the Prospect exercises the right of objection), and then archive the data until the end of the applicable legal limitation period;
- We retain the data needed to manage your request until it is completed (and then archived according to the applicable limitation period);
- With regard to the data on unrecruited candidates, we keep it in the activity database for two years, starting with the last contact with these candidates (unless they object), and then keep it in the file for four years. If candidates object to keeping their data in the active database, we keep their data in archives for six years.
5. Who do we provide your data to? Who can access your data?
Your personal data may be disclosed to third parties, as subcontractors, subject to subcontracts, providing hosting services, data analysis and marketing campaign services, contact management (CRM), communications, database management, website management and computer maintenance. These subcontractors only act according to Silkpay's instructions and only access your personal data for the purpose of performing their services. They are bound by the same security and confidentiality obligations as Silkpay.
We can also pass your data on to any third party that advises us (lawyers, accountants, auditors, etc.). In addition, to the maximum extent permitted by law, your personal data may be shared with third parties (e.g. competent authorities, partners) for the following reasons:
- In response to any type of judicial or administrative proceedings or any request from the competent authorities;
- To prevent, detect, investigate and take action against any prohibited or illegal activity, any threat to the safety or any other rights and interests of you, Silkpay or any individual, and any violation of the terms of use of this website in order to comply with legal obligations (or to enable our banking partners to comply with their legal obligations);
- When this communication is necessary to provide you with services or fulfill our contractual obligations.
Finally, Silkpay may disclose your personal data to its successors and/or potential purchasers to facilitate or permit the merger, merger, change of control or other reorganization in which Silkpay participates.
6. Have your personal data been transferred outside the EU?
The personal data collected by Silkpay is hosted within the European Union.
7. What are your rights?
Subject to applicable regulations, you have the following rights over the personal data handled by us as controllers:
- Right of access: You are entitled to (i) confirmation that your personal data has been processed or not processed and, if so, to (ii) access to such data and copies of it.
- Correction right: You have the right to request correction of inaccurate personal data. You also have the right to request incomplete personal data, including supplementary declaration.
- Right to delete: Under certain circumstances, you have the right to request the deletion of your personal data. However, this right is not absolute and Silkpay may have legitimate reasons to retain the data.
- Restriction of processing rights: Under certain circumstances, you have the right to restrict the processing of your personal data.
- Portability: You have the right to receive your personal data from you to Silkpay in a structured, common, and machine-readable format, and you have the right to transmit such data to another controller without the hindrance of Silkpay. This right only applies to the processing of your personal data based on your consent or performance of the contract, and such processing is carried out in an automated process.
- Right to Object: You have the right to object at any time and, due to your special circumstances, if the processing of your personal data is based on Silkpay's lawful interests, Silkpay may present lawful and compelling reasons for the continued processing of your personal data, in which case Silkpay may continue to process your personal data in accordance with the applicable rules. When your personal data is processed for commercial purposes, you have the right to object at any time to the processing of such data. You can object to receiving newsletters by sending email or mail to the addresses listed below. In addition, if you no longer wish to receive such messages from us, our marketing email includes a "unsubscribe" option.
- Right to send instructions on the use of your personal data after death : You have the right to send instructions to Silkpay on the use of your personal data after your death.
To exercise these rights, you can apply to the following institutions:
• Email: contact@silkpay.fr
• Or mail to: 95 AV DU PRESIDENT WILSON 93100 MONTREUIL, FRANCE
If you have difficulty handling your personal data, you can file a complaint with CNIL (3 Place de Fontenoy, 75007 Paris). Nous vous invitons toutefois à nous contacter au préalable avant d’introduire une réclamation auprès de la CNIL.