Privacy policy
Last updated: May 16, 2023
1. Who we are

1. We are Payler LTD​, company number 12535817 located at 5 Cabot Square, London, England, E14 4QA (“Payler”).

1.2. This Privacy Policy shall be read alongside, and in addition to, our Terms of Use accessible online at: (the “Terms”).

1.3. This Privacy Policy sets out how we collect and use your personal information when you use the services offered by Payler and (the “Services”) offered by Payler on the website “Website”) and the choices available to you in connection with our use of your personal information (the “Privacy Policy”).

1.4. In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

2. This privacy policy

2.1. By making the Services available, we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register on the Website and use the Services;
(b) provide true information about yourself to the extent necessary for the use of the Services;
(c) are aware of and accept this Privacy Policy.

2.2. We do not check the user information received from you, except where such a check is necessary in order for us to fulfil our obligations according to applicable laws and agreement with you.

3. Information we collect about you

3.1. In order to implement the agreement between you and us, and provide you with access to the use of the Services, we will improve, develop, and implement new features of our Services, and enhance the functionality of the available Services. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”).

3.2. We set out in more detail the information we collect when you use our Services, why we collect and process it, and the legal basis below.

3.3. General clauses, which shall apply to your use of the Website and the


● Personal Identifiers: Such as name, Business Name, Address, Phone Number, Email, IP address, Device Information, Information collected from cookies or other tracking technologies, other information necessary to establish an account.

● Records and Financial Information: Such as, bank account and routing numbers, credit and debit card information, amount you send or request.

● Information you provide when you contact us: Your response to surveys, recorded conversations, chat conversations with us, email correspondence with us, account status, repayment history, voice identification, Information about others if you choose to share it with us.

● Information from your device: including, language settings, browser ID, cookie preferences, time zone, operating system, platform, screen resolution and similar information about your device settings, data collected from cookies or other tracking technologies.

● Internet or network activity: interactions with our Services, Information about response time for web pages, download errors, date and time when you used the service, Location Information, such as your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies (“Technical Usage Data”).

3.4. We may collect Personal Information to:
Provide our Services: such as to help you send or request money, initiate a payment, add monetary value to an account, show you your account information, confirm your identity and your contact information, to authenticate your access to your account and to confirm your Account and financial information is accurate and up to date.
Manage and improve our Services: for example, to develop new products and features, for customer analysis, to administer our Services, and for internal operations, for example troubleshooting, data analysis, testing, research, and statistical purposes.
Manage fraud and risk: We conduct risk analysis, fraud prevention and risk management to protect our customers and business, including fraud that involves our partners and merchants and strategic ventures.
Communicate with you: We may contact you when you need us, such as answering a question you sent to our customer service team.

3.5. When you interact with our Services we use cookies and other tracking technologies (“Cookies”) to recognize you as a user, customize your online experiences, perform analytics; mitigate risk and prevent potential fraud, and promote trust and safety across our Services. We use Cookies to collect your device information, internet activity information, and inferences as described above.You can disable or decline some cookies for our Services. But, since some parts of our service rely on cookies to work, those services could become difficult or impossible to use.

3.6. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body, or agency, or in the defence or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.7. Please note, that if you withdraw your consent to data processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services or register with the web pages of the Website.

3.8. If we intend to further process your data for any other purpose besides those set out in this Privacy Policy, we shall provide you with details of these purposes before we commence data processing.

4. Data sharing

4.1. We do not sell Personal Information to third parties for money or share your Personal Information for cross context behavioral advertising, including any Sensitive Personal Information.

4.2. However, we will share your Personal Information with third parties to help us provide Services, protect our customers from risk and fraud, market our products, and comply with legal obligations. We may share your Personal Information to:
• Card networks and payment processors, to facilitate payment processing or to add cards to your electronic wallet.
• Fraud prevention and identity verification agencies, for example to assist us in detecting activities suggestive of fraud.
• Partners and Merchants, their service providers and others involved in a transaction, for example when you use the Services to initiate online purchases, pay other Users, or return goods we may disclose information about you and your Account with the other parties (or their service providers) involved in processing your transactions. Please note that Personal Information shared with Partners and Merchants (or their service providers) involved in a transaction is subject to the Partners and Merchants own privacy policy and procedures.

4.3. Confidentiality obligations. In case we share your data with selected third parties, we always ensure that these third parties undertake confidentiality obligations regarding your personal data collected while you use of the services or applications they offer. We will not share your personal data outside the scope of purposes specified in this Privacy Policy without your prior consent.

4.4. Sharing in the general conduct of business. We may also share your data with our affiliates and keep some of your personal information in our business records for the accounting and compliance purposes. As such, you hereby consent that we may also transfer your personal information to a third party if we decide to transfer or sale of all or substantially all of our business to which this Privacy Policy relates to, whether by merger, sale of stock, sale of assets, or otherwise, if permitted by and done in accordance with applicable law, so you can continue to receive service and information in connection with that business with as little disruption as possible. Similarly, you hereby consent that in that case your personal data will be processed by our successor or assignee in accordance with this Privacy Policy.

4.5. Disclosure to tax authorities. We reserve the right to disclose your personal information to tax authorities in case it is necessary because of your participation in public tournaments. We may also publish your data as part of the tournament score tables on our and third party Websites.

4.6. Disclosure required by law. We reserve the right to disclose your personal information as required by law, by court order or in special cases when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action if you or third parties are violating the Terms, any other terms of services provided by us or our affiliates or any applicable law, for the purpose of defence of our rights and interests. We also reserve the right to disclose your personal information if we have a good faith belief that it is necessary to prevent fraud or other illegal activities.

5. International transfers

5.1. We may transfer and maintain some of your personal information on our servers or databases outside the European Economic Area (EEA), including in CIS.

5.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

6. Retention periods

6.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

6.2. You may delete your personal data by removing the data from your account; alternatively, you can delete your account.

6.3. You may request to remove your account and data on our Services by contacting the service support (see section 10 for details).

7. Your rights

7.1. You have the following rights, in certain circumstances, in relation to your personal information:

(a) Right to access your personal information.

(b) Right to rectify your personal information: you can request that we update, block, or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received, or no longer relevant for the purpose of processing.

(c) Right to restrict the use of your personal information.

(d) Right to request that your personal information is erased if:
• it is no longer required in relation to the purposes for which it was gathered or processed in another way;
• you withdraw your consent concerning processing subject to consent;
• you are justifiably opposed to the processing;
• it has been subject to illicit processing; or
• it is imposed by law.

(e) Right to object to processing of your personal information.

(f) Right to data portability (in certain specific circumstances).

(g) Right not to be subject to an automated decision.

(h) Right to lodge a complaint with a supervisory authority.

(i) For processing based upon your consent, the right withdraw that consent at any time.

(j) You may have other rights under your legislation of your country of residence, including right to define the instructions relative to the outcome of your personal data after your death.

7.2. You also have the right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you.

7.3. If you would like to exercise these rights, please contact service support at or send your request to us in writing to Cabot Square, London, England, E14 4QA. We will aim to respond to you within 30 days from the date of receipt of your request. We will need to verify your identity before we are able to disclose any personal data to you.

8. Security measures

8.1. We take technical, organisational, and legal measures, including, where suitable, encryption, to ensure that your personal data is protected from unauthorised or accidental access, deletion, modification, blocking, copying, and dissemination.

8.2. Access to the Services is authorised using your login (e-mail address) and password. You are responsible for keeping this information confidential. You shall not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.
8.3. If you forget your login details, you can request us to send you an e-mail, which will contain a restoration code.

8.4. To reduce the probability of third parties gaining unauthorised access, if you login to your account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your account. You will then need to contact service support and provide certain additional information to verify your credentials and gain access to your account.

9. Changes to this policy

9.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation archive. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to them.


10.1. If you have any questions, please send your enquiries to service support at or send your request to us in writing to Cabot Square, London, England, E14 4QA. Please quote this Privacy Policy so we can deal with your enquiry efficiently. We will aim to respond to you within 30 days from receipt of your request.

10.2. All correspondence received by us from you (written or electronic enquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for responding to the enquiry, except as expressly provided by law.