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PCS Pro privacy policy

This English translation is provided for information only. In case of discrepancy, the French version prevails. CREACARD (hereinafter “we”) collects personal data and uses it in various automated processing operations. The automated processing of personal data is governed in particular by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, hereinafter the “GDPR”, and by French Law no. 78-17 of 6 January 1978 on information technology, data files and civil liberties.

This is CREACARD's Privacy Policy for its PCS PRO offer, intended to inform you of how we protect your personal data. It applies to all PCS PRO products and services sold by CREACARD.

CREACARD is a French public limited company (Société Anonyme) with share capital of €6,532,960, registered with the Paris Trade and Companies Register under number 520 833 302, located at TSA 11765, 75771 PARIS CEDEX 16, FRANCE.

CREACARD is an electronic money distributor offering rechargeable PCS MASTERCARD® payment solutions and cards and electronic money top-ups, issued by PFS Card Services (Ireland) Limited (part of EML PAYMENTS), an electronic money institution authorised by the UK supervisory authority, the Financial Conduct Authority (FCA).

1. Who is the controller of your personal data?

The controller of your personal data is CREACARD, located at TSA 11765, 75771 PARIS CEDEX 16, FRANCE.

2. What personal data do we collect?

We collect and use the personal data that is strictly necessary for our business in order to offer you personalised, quality products and services.

We may collect various categories of personal data from you, including:

  • identification and contact information (last name, first name, gender, date of birth, town/department/country of birth, photo, employment status and business sector, identity documents);
  • contact details (postal and email address, phone number);
  • identification and authentication data, in particular when using online account services (technical logs, computer traces, information on device security and use, IP address);
  • banking and financial information and transaction data (bank details, card number);
  • transaction data, including information on operations;
  • data relating to the use of the products and services subscribed to (banking, financial and transaction data, including wealth level, monthly income bracket, bank account data, transaction information).

When you change your information yourself in your personal area, CREACARD may collect new personal data about you (phone number, postal address).

3. Purposes of processing your personal data

When you subscribe to the PCS PRO services offered by CREACARD, your personal data is processed for the following purposes.

a. To comply with our legal and regulatory obligations

Your personal data is processed to fulfil various legal and regulatory obligations, including:

  • combating money laundering and terrorist financing;
  • compliance with applicable legislation on international sanctions, asset freezes and embargoes;
  • combating money laundering, service abuse and tax fraud;
  • responding to official requests from duly authorised public or judicial authorities, in connection with the prevention and/or detection of offences and crimes.

b. To perform the contract or provide you with pre-contractual information at your request

We use your personal data to enter into and perform our contracts, in particular to:

  • provide you with information about our products and services;
  • provide you with support in relation to our products and services, in particular the banking transactions carried out;
  • provide you with gift card or prepaid card services subject to our contractual obligations;
  • provide you with e-wallet services;
  • process your account information;
  • verify your identity;
  • assist you with your requests;
  • manage the customer relationship, in particular the management and performance of the products and services we sell;
  • improve the products and services we provide to you.

c. For the pursuit of our legitimate interests

Finally, we use your personal data to set up and develop our products or services, including for the purposes of:

  • keeping proof of transactions or operations;
  • risk management;
  • updating customer knowledge;
  • monitoring transactions to identify those that appear unusual;
  • developing and improving our products and services.

4. Lawfulness of processing your personal data

By consenting to this privacy policy, you give us permission to process your personal data for the reasons specifically identified above. Consent is required for CREACARD to process your personal data, but it must be given explicitly. When we ask you for sensitive information, we will always tell you how and why we use your information.

The uses described above are based on:

  • the performance of the contract entered into with CREACARD;
  • legal and regulatory texts (this is the case in particular for all processing related to customer due diligence, combating money laundering, terrorist financing and fraud, compliance with international sanctions…);
  • our legitimate interest (for example, risk prevention, developing CREACARD's business, commercial prospecting operations);
  • for more specific uses, your consent.

Your personal data (photo) may be subject to processing involving automated decision-making by our provider EML. This processing is necessarily based on one of the legal bases set out above.

5. Recipients of your personal data

Your personal data is mainly intended for CREACARD, for the purposes set out in this privacy policy.

Your personal data may also be passed on to the following third parties for the following purposes:

  • the issuer of PCS cards (the electronic money institution EML PAYMENTS);
  • legally authorised administrative and judicial authorities, for the performance of their duties, on request and within the limits permitted by regulations;
  • certain regulated professions such as lawyers, notaries, bailiffs or statutory auditors, in the performance of their duties.

6. Retention period of your personal data

Personal data is kept for as long as necessary to provide the products and services offered by CREACARD, to comply with regulatory obligations and to keep contractual evidence, until the parties' rights are extinguished.

  • Provision of products and services, performance of the contract: 5 years from the end of the business relationship.
  • Support in connection with banking transactions: 5 years from the end of the business relationship.
  • Improvement of products and services: 3 years from the close of the financial year concerned.
  • Accounting records and supporting documents: 10 years from the close of the financial year concerned.
  • Identity documents: 15 days from collection.
  • Commercial prospecting aimed at an existing customer: 5 years from the end of the business relationship.
  • Prevention and detection of offences and crimes, and more generally processing related to our legal and regulatory obligations: 5 years from the discovery of the offence. In the event of legal proceedings, data is kept until their conclusion and then for the applicable statutory limitation period.
  • Recording of telephone conversations: 1 month from the recording of the conversation.
  • Cookies, trackers: maximum 13 months from collection (see the cookie policy).
  • Data collected via cookies: 25 months from collection.

The periods above may be extended to meet our legal and/or regulatory obligations. Once the retention period has expired, your personal data will be destroyed or anonymised.

7. Your rights

As a data subject, you have the following rights over your personal data, which you can exercise at any time:

  • right of access: you have the right to request a copy of the information we hold about you;
  • right to rectification: you have the right to correct inaccurate or incomplete data we hold about you;
  • right to erasure: you can ask for the personal data we hold about you to be erased from our records in certain situations. Your data relating to your financial transactions, accounts and cards cannot be erased, under national law on the prevention of fraud, money laundering, terrorist financing or the misuse of services for criminal purposes;
  • right to withdraw your consent: you can tell us at any time that you wish to withdraw your consent to the processing of your data by CREACARD;
  • right to restriction of processing: where certain conditions apply, you are entitled to restrict processing;
  • right to object: you have the right to object to certain types of processing such as direct marketing, as well as automated processing, including profiling;
  • right to give instructions on what happens to your data after your death.

Please note that exercising some of these rights may, on a case-by-case basis, make it impossible for CREACARD to provide the product or service. You can contact us at DPO@creacard.net for more information.

You can also, at any time, free of charge and without having to give reasons, object to your data being used for commercial prospecting.

All the above requests will also be passed on to any third parties who may be involved in processing your personal data.

8. Data protection officer

You can exercise your rights at any time by contacting CREACARD and enclosing a copy of an ID document with your request, by post to the data protection officer:

CREACARD
Data Protection Officer
TSA 11765
75771 PARIS CEDEX 16
FRANCE

Or by email: DPO@creacard.net

You also have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the supervisory authority responsible for compliance with personal data obligations: https://www.cnil.fr/fr/plaintes.

9. Changes to the policy

This privacy policy may change. It is your responsibility to read the latest version of this document on our website. Any substantial change will be brought to your attention.