Who we are?
Total Processing is a payment technology company who offer services that enable platforms and merchants to run businesses, and to safely conduct online payment transactions.
This Privacy Notice describes the types of Personal Data we collect through our products and merchant services (“Services”) and via our online presence, which include our website https://www.totalprocessing.com (our “Site”).
This notice also describes how we use Personal Data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This notice does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third parties carefully.
Our Data Protection Officer
Total Processing have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. Total Processing will try and respond to all requests within one calendar month.
Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Email address: [email protected]
Data Protection Officer
Total Processing Ltd.
111 Piccadilly, Manchester M1 2HY, United Kingdom
Alternatively, if you are dissatisfied with the way your information is handled, you have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioners Office (ICO).
The Information Commissioner’s Office Wycliffe House Cheshire SK9 5AF
Helpline: 0303 123 1113 (local rate)
Email: [email protected]
Personal Data we collect
Under Data Protection Laws, Total Processing acts as a “data controller” and a “data processor” dependent on the activity that it performs.
Total Processing is a data controller when it determines the purposes and means of the processing taking place. These data processing activities include:
- providing Total Processing products and services;
- monitoring, preventing and detecting fraudulent payment transactions and other fraudulent activity;
- complying with legal or regulatory obligations applicable to the financial sector to which Total Processing Limited is subject, and;
- analysing, developing and improving Total Processing Limited products and services.
- Total Processing is defined as a data processor where it facilitates payment transactions on behalf of and at the direction of a Merchant.
Personal Data that we collect about you.
Total Processing may obtain Personal Data about you from various sources to provide our Services and to manage our Sites. Total Processing will generally not collect your Personal Data directly from you. If you have carried out a payment with a Total Processing Merchant, your agreement with the relevant Total Processing Merchant should explain how they share your Personal Data with Total Processing, and if you have questions about this sharing, then you should direct those questions to the appropriate Total Processing Merchant.
Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites will be apparent from the context in which you provide the data. In particular:
- When you complete our online form for Total Processing Services we collect your full name, email address, telephone number.
- When you respond to Total Processing emails we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Total Processing. If you contact us by phone as a Total Processing Merchant, we may collect additional information in order to verify your identity.
- If you are a Total Processing Merchant, you will provide your contact details, such as name, postal address, telephone number, and email address. As part of your business relationship with us, we may also receive financial and personal information about you, such as your date of birth and government identifiers associated with you and your organisation (such as your, tax number, social security number or Employer Identification Number).
- If you are a Cardholder, when you make payments or conduct transactions through a Total Processing Merchants website or application, we may receive your transaction information. Depending on how the Total Processing Merchant implements our Services, we may receive this information directly from you, or from the Total Processing Merchant. The information that we collect will include payment method information (such as credit or debit card information, purchase amount, date of purchase, and payment method). Different payment methods may require the collection of different categories of information. The Total Processing Merchant will determine the payment methods that it enables you to use, and the payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you by the Total Processing Merchant.
- When we conduct fraud monitoring, prevention and detection activities, we may also receive Personal Data about you from our partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may use technology that helps us assess the risk associated with an attempted transaction that is enabled on the Total Processing Merchant’s website or the application that collects information.
You may also choose to submit information to us via other methods, including:
- (i) in response to marketing or other communications,
- (ii) through social media or online forums,
- (iii) through participation in an offer, program or promotion,
- (iv) in connection with an actual or potential business relationship with us, or
- (v) by giving us your business card or contact details at trade shows or other events.
Information that we collect automatically on our Sites.
- Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
- Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
We also may collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We use Google Analytics on our Sites to help us analyse your use of our sites and diagnose technical issues.
How we use personal data
Our products and services.
We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our Merchants, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete payment transactions and to provide payment-related services to our Merchants.
Marketing and events-related communications.
We may send you email marketing communications about Total Processing products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. When we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.
When you visit our Sites or online services, we collect information about your online activities over time to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). Where required by applicable law, we will obtain your consent prior to processing of your information for the purpose of interest-based advertising.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to Merchants based on a range of factors, including demographic data, Merchant’s inferred interests and browsing context (for example, the time and date of your visit to our Sites, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.
We use personal data of existing and prospective merchants in order to verify the identity, suitability, and risks involved with maintaining a business relationship. This is legally required to cover “Anti-Money Laundering (“AML”) and Know-Your-Customer (“KYC”)” obligations.
Legal Basis for processing
We will process your personal data in the following circumstances:
Type of Data processed
Legal Basis for processing
To facilitate and enable our relationship with you as a prospective, new or existing merchant.
Identity and contact details
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (for running our business and to prevent fraud)
To process and execute your transaction, and other payments related activities, including: Manage payments, fees and charges Collect and recover funds for our business purposes
Identity, contact details and transaction details
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (for running our business and to prevent fraud) Processing of your personal data for this purpose may include automated decision-making
Identity and contact details
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Technical, device and usage details
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant and to develop our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Identity, contacts and technical details
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud) Necessary to comply with a legal obligation
To verify existing and prospective merchants in order to verify the identity, suitability, and risks involved with maintaining a business relationship.
Identity and contact details, financial details
Necessary for our legitimate interests (for running our business and to prevent fraud) Necessary to comply with a legal obligation
How We Disclose Personal Data
Total Processing does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.
- Total Processing. We share Personal Data with other Total Processing entities in order to provide our Services and for internal administration purposes.
- Service providers. We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorise such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.
- Business partners. We share Personal Data with third party business partners when this is necessary to provide our Services to our Merchants. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment schemes (such as credit card networks) when we provide payment processing services.
- We share data with parties directly authorised by a Merchant to receive Personal Data. The use of Personal Data by an authorised third party is subject to the third party’s privacy notice.
- Corporate transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganisation, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.
- We share Personal Data as we believe necessary: (i) to comply with applicable laws and regulations, including payment scheme rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Total Processing, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
Your Rights and Choices
You have choices regarding our use and disclosure of your Personal Data:
Opting out of receiving electronic communications from us.
If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.
How you can see or change your account Personal Data.
If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to your Total Processing account or by contacting us.
Your data protection rights.
Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:
- The right to request confirmation of whether Total Processing processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
- The right to request that Total Processing rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
- The right to request that Total Processing erase your Personal Data in certain circumstances provided by law;
- The right to request that Total Processing restrict the use of your Personal Data in certain circumstances, such as while Total Processing considers another request that you have submitted (including a request that Total Processing make an update to your Personal Data); and
- The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.
- The right to object to processing of your data where:
- Processing is based on legitimate interests;
- Processing involves automated decision-making and profiling; Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.
Process for exercising data protection rights.
We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.
We will aim to respond to your request within a calendar month unless the request needs to be extended if it’s a manifestly unfounded or excessive request but we will let you know within the first month.
For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
If you are a Customer of a Total Processing Merchant, please direct your requests directly to them. For example, if you are making, or have made, a purchase from a business using Total Processing Services, and you have a request that is related to the payment information that you provided as part of the purchase transaction, then you should address your request directly to the merchant.
For more information in relation to Data Subject rights and how to request information please contact [email protected]
Security and Retention
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organisational, technical and administrative measures designed to protect Personal Data within our organisation against unauthorised access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties, all of which have been trained on how to handle information securely.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact our Data Protection officer immediately.
We are PCI DSS (Payment Card Industry Data Security Standard) compliant, which is the standard set by the payment card industry to ensure that credit card data is processed, stored or transmitted in a secure environment.
If you are a Total Processing Merchant, we retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services to you, even if you close your Total Processing account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention.
We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
International Data Transfers
We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy notice. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.
Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: International Data Transfer Agreements (ITDA), Standard Contractual Clauses with a data recipient outside the EEA, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the required international transfer laws.
Links to other websites
The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.
If You have any questions, please contact [email protected]
Updates to this Privacy Notice and Notifications
We may change this Privacy Notice from time to time to reflect new services, changes in our Personal Data practices or relevant laws.
Any changes are effective when we post the revised Privacy Notice on the Services. We may provide you with disclosures and alerts regarding the Privacy Notice or Personal Data collected by posting them on our website and, if you are a Merchant, by contacting you through your Total Processing Account Manager, email address and/or the physical address listed in your Total Processing account.
Date privacy notice last updated: November 2022