Privacy Policy

At InstaPaid, we understand the importance of your privacy and are committed to protecting your personal information.

This Privacy Policy explains how InstaPaid ApS (collectively “we”, “our” or “us”)  collect, use, disclose, and protect your information when you use our early wage access services.

The legal entity responsible for the processing of your data is:

InstaPaid ApS
Carl Von Rosensvej 26
2950 Vedbæk
Denmark

CVR 43769359

InstaPaid ApS can be contacted on [email protected].

This privacy policy applies to personal data that you provide to us in connection with the use of InstaPaid, via inquiries regarding our product and data which we collect through our website, InstaPaid.io.

1. Collection of information

1.1 Your visit to InstaPaid.io

1.1.1. What data do we collect when visiting InstaPaid.io?

We automatically collect data about you and your use of our website when you visit InstaPaid.io. This information is i.a., what type of browser you use, your search terms on InstaPaid.io, your IP address, including your network location, and information about the electronic device used. In addition to our privacy policy, our cookie policy also applies when using InstaPaid.io.

1.1.2. What is the purpose of collecting your personal data in connection with your visit to our website?

The purpose of the collection is to optimize the user experience and functionalities on InstaPaid. Furthermore, the purpose is to use the data collected for targeted marketing, including retargeting through e.g., social media like LinkedIn or search engines like Google. This processing of your data is necessary so that we can take care of our interests in the ongoing work of improving and optimizing the website and show you relevant offers and services.

1.1.3. Legal basis

The legal basis for the processing is Article 6 (1) (a), (f) of the General Data Protection Regulation (EU 2016/679).

1.2. Your use of InstaPaid and your communication with us

1.2.1 What data do we collect about your use of InstaPaid and in your communication with us?

In connection with your use of InstaPaid or communication with us, we may collect the following types of information:

• Personal Information: We may collect personal information, such as your name, address, date of birth, social security number, bank account information, and employment information, when you sign up for our services and when you request early wage access.
• Usage Information: We may collect information about how you use our services, including the pages you visit, the features you use, and the actions you take.
• Device Information: We may collect information about the device you use to access our services, including the type of device, operating system, and browser.
• Log Information: We may collect log information when you use our services, including your IP address, browser type, and the date and time of your visit.

 

1.2.2. What is the purpose of collecting personal data in connection with the use on InstaPaid and in your communication with us?

The purpose of collecting and processing data is that we want to abide by our agreement with your employer, including delivering the services outlined in our agreement.  This include:

• To provide and improve our early wage access services
• To personalize your experience
• To communicate with you about our services, promotions, and updates
• To verify your identity and eligibility for early wage access
• To process early wage access requests and payments
• To detect and prevent fraud and unauthorized access to our services
• To comply with legal and regulatory requirements

 

In addition, we may use information about your use to comply with various legal requirements, including bookkeeping, accounting, and when withdrawing payments.

1.2.3. Legal basis

The legal basis for the processing is Article 6 (1) (b), (c) and (f) of the General Data Protection Regulation (EU 2016/679).

1.3.

1.3.1. Collection of data using newsletters

When you have subscribed to the newsletter from us, we collect information about your name, e-mail address, and possibly a mobile number.

1.3.2. What is the purpose of collecting data using newsletters?

The purpose is to take care of our interest in being able to deliver newsletters to you.

1.3.3. Legal basis

The legal basis for the processing is Article 6 (1)(a) of the General Data Protection Regulation (EU 2016/679).

2. Recipients of personal data

2.1. Disclosure of your data to external partners

We may leave your data to external partners who process the information on our behalf. These external partners can, i.a. be employers, partners who handle the technical operation and improvements of our systems and website, sending out newsletters and targeted marketing, including retargeting and for your assessment of our company and products.

• Employers: We may share your information with your employer or payroll provider to verify your employment and eligibility for early wage access.
• Service Providers: We may share your information with third-party service providers who perform services on our behalf, such as payment processing, customer support, and analytics.
• Financial Institutions: We may share your information with financial institutions and payment processors to facilitate early wage access transactions.
• Business Partners: We may share your information with our business partners to offer you promotions and special offers.
• Legal and Regulatory Authorities: We may share your information to comply with legal and regulatory requirements, such as a court order or subpoena.

 

Written data processor agreements have been entered into for all data responsible. No data processors may use the data collected for any purpose other than to fulfill the contract between us and the data responsible. We are subject to confidentiality.

2.2. Disclosure of your information to data processors outside the EU/EEA

To the extent that we use data processors established outside the EU/EEA, data processing will always comply with valid transfer guarantees in the form of standard contract clauses (SCC) according to Article 46 of the General Data Protection Regulation (EU 2016/679).

3. Your rights

3.1. The right of access

You are always entitled to request us to provide information, including what data we have registered about you, what purpose the registration serves, what categories of personal data and recipients of data that may be, and information on where the data comes from.

You have the right to receive a copy of the personal data that we process about you. If you want a copy of your personal information, you must send a written request to [email protected]. You will be asked to document that you are whom you pretend to be.

3.2. The right to rectification

You have the right to have incorrect personal data about yourself corrected by us. If you become aware that there are errors in the data that we have registered about you, you are encouraged to contact us in writing so that the data can be corrected. You will be asked to document that you are whom you pretend to be.

3.3. The right to be forgotten

You have the right to request the deletion of your personal information that we have collected and stored. To exercise this right, please contact us at [email protected]. We will process your request within [insert time frame] and will notify you of the outcome. Please note that we may be required to retain certain information for legal or regulatory purposes. If we are unable to comply with your request for any reason, we will explain the reason to you. Additionally, you have the right to withdraw your consent to our collection and processing of your personal information at any time. Please note that withdrawing your consent may result in the termination of your access to our services. To withdraw your consent, please contact us at [email protected].

3.4. The right to limit the treatment to storage

In certain cases, you have the right to have the processing of your data limited to only storage, e.g., if you believe that the information we process about you is incorrect.

3.5. The right to data portability

In certain cases, you have the right to have personal information that you have provided to us provided in a structured, commonly used, and machine-readable format and have the right to transfer this information to another data controller.

3.6. The right to object

You have the right to object to our processing of your personal data, with a view to direct marketing, including the profiling, to target our direct marketing, as this processing is carried out on the basis of our legitimate interests, cf. 1.1. and 1.2. If you do not want us to use your personal information for direct marketing and profiling, you must delete your cookies, as described in our cookie policy.

3.7. The right to withdraw consent

You have the right to revoke the consent you have given us and forgive the processing of personal data, including for the transmission of newsletters.

3.8. The right to complain

You can always complain to a data protection authority, e.g. The Danish Data Protection Agency.

You can make use of your rights by writing to [email protected].

3.9 Children’s privacy

Our services are not directed to children under the age of 13. We do not knowingly collect personal information from children under the age of 13.

4. Deletion of personal data

4.1. Data collected in connection with your use of InstaPaid.io, cf. section 1.1.

Data collected about your use of InstaPaid.io in accordance with section 1.1., is deleted according to the rules in our cookie policy. The cookies that InstaPaid.io itself provides are deleted no later than 12 months after you last visited the site, while third-party cookies have varying expiry deadlines.

4.2. Data collected in connection with your use, cf. 1.2.

Data that we collect in connection with your use on InstaPaid, cf. 1.2., will be deleted two years after your use. However, we reserve the right to store the information for a longer period if we have a legitimate basis for longer storage – this may be the case, for example, if it is necessary for a legal claim to be established, asserted, or defended, or if the storage is required to we can comply with legal requirements.

4.3. Data collected by using of newsletters, cf. 1.3

Information collected in connection with your subscription to our newsletter, cf. 1.3., will be deleted when your consent to the newsletter is withdrawn unless we have another basis for processing the information.

5. Security

5.1. Technical measures

We have implemented appropriate technical and organizational security measures against the accidental or unlawful destruction, loss, alteration, or deterioration of personal data and against the disclosure or misuse of unauthorized persons.

5.2. Employee access to your information 

Only employees who have a real need to access your personal information to carry out their work have access to it.

6. Changes in our privacy policy

6.1. Right to change our privacy policy

We may update this Privacy Policy from time to time. We will post the updated Privacy Policy on our website and notify you of any material changes.

 

Last updated: 16 January 2023