Privacy
policy
Welcome to the privacy policy of LA Orange CY Limited.
La Orange CY Limited operates under the tradename and domain ‘JETON’ (www.jeton-app.com). La Orange CY Limited is incorporated in the Republic of Cyprus under the provisions of the Companies Law (Cap113) with registration number HE424897. La Orange CY Limited is authorized by the Central Bank of Cyprus under Electronic Money Law for distributing or redeeming electronic money (e-money), with License No: 115.1.3.66.
Jeton respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy policy supplements our Terms & Conditions, please refer to them for any defined terms referred to in this privacy policy not defined in this policy.
This privacy policy applies to your personal information when you (or the business entity you represent) access our website or apply for use of our products and services and when you use our products and services. If you choose not to give Us Your personal information, it may delay or prevent us from meeting our obligations. We may be unable or prohibited to provide services to you (or the business entity you represent). Further, We may terminate provision of services to you (or the business entity you represent).
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
This privacy policy aims to give you information on how Jeton collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to use Jeton’s products and services. This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy policy supplements other notices and privacy policies and is not intended to override them.
Jeton is made up of different legal entities, details of which can be found here: www.jeton-app.com
This privacy policy is issued on behalf of the Jeton Group so when we mention "Jeton", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Jeton Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Jeton is the controller and responsible for this website.
We have appointed a team who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the team using the details set out below.
Contact details: dpo@jeton.com
If you have any questions about this privacy policy or our privacy practices, please contact our relevant team.
We keep our privacy policy under regular review. This version was last updated in April 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements nor their operations. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the Terms & Conditions, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products and services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Technical Data from the following parties:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please, contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer and to ensure your continued eligibility as a customer. We may only make positive decisions (to register you or confirm your eligibility) automatically and we will not make negative automated decisions about you. | a. Identity b. Contact | Performance of a contract with you |
| To process and provide services including: Manage payments, fees and charges Collect and recover money owed to us | a. Identity b. Contact c. Financial d. Transaction e. Marketing and Communications | a. Performance of a contract with you b. Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: a. Notifying you about changes to our terms or privacy policy b. Asking you to leave a review or take a survey | a. Identity b. Contact c. Profile d. Marketing and Communications | a. Performance of a contract with you b. Necessary to comply with a legal obligation c. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | a. Identity b. Contact c. Profile d. Usage e. Marketing and Communications | a. Performance of a contract with you b. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, customer support, reporting and hosting of data and improvements to the website and services) | a. Identity b. Contact c. Technical | a. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) b. Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | a. Identity b. Contact c. Profile d. Usage e. Marketing and Communications f. Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | a. Technical b. Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about products or services that may be of interest to you | a. Identity b. Contact c. Technical d. Usage e. Profile f. Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of use of Your Account including transactions.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible
with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your information with trusted third parties when:
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Jeton Group. This will involve transferring your data outside the EU wherever members of the Group are located.
Many of our external third parties are based outside the EU so their processing of your personal data will involve a transfer of data outside the EU.
Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.
We may be obligated to disclose any personal data to any relevant competent authority as may be required under the Law from time to time in any of the following situations:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for ten years after they cease being customers.
In some circumstances you can ask us to delete your data: see your Legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please contact us at dpo@jeton.com in order to find out more about these rights, which are given below:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one 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
We gather, use and may disclose data on our merchant accounts. When a merchant registers for a Jeton App Account, they are required to provide information about their business in order to perform relevant credit and risk assessments. This includes collecting information about merchant’s key controllers, the directors, partners, and shareholders and confidential information. Jeton shall use your Confidential Information only for the purposes of the evaluation set out in the Terms and Conditions and privacy policy and not for any other commercial or operational purpose, nor in connection with any similar project undertaken by it, nor in any manner detrimental to you, its affiliates or their respective representatives. In addition to these specific obligations, Jeton shall protect and safeguard your confidential information with at least the same degree of care with which it protects and safeguards its own confidential information.
By accepting the Terms and Conditions and privacy policy, you also agree that you shall not use or disclose Jeton's Confidential Information other than the way Jeton uses or discloses Your Confidential Information.
This information is used to verify our merchants and their key controllers. This includes verifying certain data provided by our merchants and reviewing their eligibility to use our product and services. Third party partners may be used to validate the information provided by you at account registration.
Jeton reserves the right to periodically review merchant accounts. This may involve the request of a credit reference from a credit or fraud agency on any merchant account. As part of this review Jeton reserves the right to close an account based on the information found.
For different merchant accounts, we may collect information about a merchant's business and online profile in order to review a merchant’s size, customer base, and expected transactional activity.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We may update this Privacy Statement from time to time by publishing a new version on our website. You should check this page occasionally to ensure You are happy with any changes. If the changes are substantial, we may notify you of changes by email.
Further information and/or queries and/or requests regarding the processing of Your personal data and any of Your rights with respect to Your personal data can be requested by contacting us in writing as follows:
By email: dpo@jeton.com
By phone: +35725588665
By post: Vashiotis Seafront Offices3107, 28 October Ave 364,Office no :402Limassol, Cyprus