End-user data policy

This is the data we store about any user who has created an account with one of our clients via our paywall solution.

 

Personal data type Why we have it – purpose Where we got it Where is it stored Who is involved (has access) Legal basis How long do we keep it Can it be deleted? Then how? Please note
End-user personal information (email, fullname, password for access) To provide authetntication flow and store user information throughout our system for payments, subscriptions and access to assets End user (Individual) provides it upon registration (by filling in the registration form) Database & ElasticSearch (for website: In our storage system) Merchants have access to their end users data, while admin users have access to all. By registring through our Paywall and the Terms are accepted. Until the user is deleted Data obfuscated as part of our Erase Account feature
Additional end-user information (country, region/continent, IP address, device used for registration) To gather analytics for ourselves and towards our merchants (e.g. location where users are mostly buying from). In addition, the location related information is important in the payments records so that merchants can determine whether they should cover tax costs or not End user (Individual) provides it upon registration (automatically gathered by our system, not entered in the registration form) ElasticSearch (for website: In our storage system) Merchants can see this in the merchant panel for their end users, while admin users can see this information for all. By registring through our Paywall and the Terms are accepted. Until the user is deleted Location data is kept for bookeeping purposes even after the account is deleted, until it is not needed anymore. All other data can be obfuscated or deleted. Some information such as the IP address will be obfuscated, however the location related information are needed as information towards our merchants even after a user is deleted in order to determine whether they should cover taxes or not.
End-user Metadata (custom registration fields, register source) Merchants define these custom registration fields in order to gather additional insights for their audience End user (Individual) provides it upon registration (part of the registration form) Database & ElasticSearch (for website: In our storage system) Merchants can see this in the merchant panel and in reports they generate By registring through our Paywall and the Terms are accepted. Until the user is deleted Yes, and we will fully delete this information with the Erase Account feature
End-user Account Logins Information (+ location data and device used for logging in) To provide our service and charge clients. This information is also used to gather analytics (e.g. devices mostly used for accessing content) We record it when end user logs in on their merchant’s website ElasticSearch (for website: In our storage system) Merchants can generate a report with this information By registring through our Paywall and the Terms are accepted. Until the user is deleted User data part of these records can be obfuscated We will not fully delete these records because one way we charge our clients is for unique logins in a specific timeframe
Action records – Payments To provide our service and charge clients End-user provides it when paying for an asset Database & ElasticSearch (for website: In our storage system) Merchants & Admin users can see this information By registring through our Paywall and the Terms are accepted. Minimum 10 years It will not be deleted, nor obfuscated (check note) Due to legal legislations, such as money laundrying regulations, we are required to keep this data in our system
Action records – Subscriptions To provide our service and charge clients End-user provides it when subscribing for a premium content on their merchant’s website Database & ElasticSearch (for website: In our storage system) Merchants & Admin users can see this information By registring through our Paywall and the Terms are accepted. Until the user is deleted It will not be deleted, nor obfuscated (check note)
Action records – Access To provide our service and charge clients End-user provides it when purchasing (ppv or subscription) an asset and by that getting access for a premium content on their merchant’s website Database & ElasticSearch (for website: In our storage system) Merchants & Admin users can see this information By registring through our Paywall and the Terms are accepted. Until the user is deleted The personal data which is part of the Assets Access Records in our system will be obfuscated and not available for merchants or admin users to see it
Action records – Adding users to vouchers To provide our service and charge clients Merchants specify it when adding end-user email addresses to a specific voucher Database (for website: In our storage system) Merchants & Admin users can see this information By registring through our Paywall and the Terms are accepted. Until the user is deleted It is fully deleted using in case the end-user account gets deleted

Manage your data

Go to your account page in the paywall interface. There are two options available to you; export all data, and delete account. If you choose to export al your data you will receive an email with a json file including everything we have about you. If you choose delete account, we will delete any and all information that is not directly necessary for bookkeeping or compliance purposes due to legislations governing monetary transactions. In the cases where we need to keep some data for compliance reasons not tied to your person (like location) – we will obfuscate (anonymise) the personal details.

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