Privacy Policy for PayPal Services |
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This Privacy Policy applies to users in all European Union countries where the PayPal “send only” service is offered. These are Bulgaria, Cyprus, Estonia, Gibraltar, Latvia, Liechtenstein, Lithuania, Malta, Romania, San Marino, Slovakia, Slovenia and Vatican City State. To view the Privacy Policy for a different country or region, please click the appropriate link above.
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This Policy was last modified on November 10, 2008.
The Privacy Policy below governs your PayPal account and any information you provide on this site.
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Overview
In order to operate the PayPal service and to reduce the risk of fraud, PayPal (Europe) S.à r.l. & Cie, S.C.A. ("PayPal" or "we"), the data controller, must ask you to provide us information about yourself and your credit or debit card and/or bank account. By consenting to, and agreeing the terms of, the Privacy Policy, you also expressly consent and agree to us processing your data in the manner set out in the Privacy Policy. This Privacy Policy describes the information we collect and how we use that information. PayPal takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, in order for us to offer our services to our users; to enhance the quality of its service from time to time; and to protect the interests of our users, we will in limited circumstances and as further described in more detail throughout this policy, share some of your information with third parties under strict restrictions. It is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the PayPal website.
By accepting the Privacy Policy and User Agreement in registration, you expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the PayPal User Agreement.
Your privacy is important to us. Please note that by accepting this Privacy Policy, you consent to your personally identifiable information being stored and processed on our parent company's (PayPal Inc) computers in the United States, as set out in the section entitled, “Disclosure to Third Parties Other Than PayPal Customers” below. The laws on holding personal data in the United States may be less stringent than Luxembourg laws but as we explain below, we will hold and transmit your personal information in a manner designed to ensure its security. If you disagree with the terms of Privacy Policy, please do not register for nor use the PayPal service.
Notification of Changes
This policy may be revised over time as new features are added to the PayPal service or as we incorporate suggestions from our customers. We may amend this Privacy Policy at any time by posting a revised version on our web site. The revised version will be effective at the time we post it. In addition, if we propose to change this Privacy Policy in a substantial manner, we will provide you with at least 30 days’ prior notice of such a change by posting notice on the “Policy Updates” page of our web site(s). After this 30 days notice, you will be considered as having expressly consented to all amendments to the Privacy Policy. If you disagree with the terms of this Privacy Policy, you may close your account at any time.
As stated above, we will post the amended Privacy Policy prominently on our Website so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the PayPal website at https://www.paypal.com/cy/ at any time for the most current version of our Privacy Policy.
Some pages on the PayPal website include links to third party websites. These sites are governed by their own privacy statements, and PayPal is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party Websites should review the privacy statement of these sites before providing them with personally identifiable information.
A Special Note About Children. Children are not eligible to use our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service.
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Information We Collect
Required Information
To open a PayPal account, you must provide your name, address, phone number, and email address. In order to make certain payments through PayPal, you must provide credit card, debit card or bank account information. We also ask you to choose two different security questions to answer (such as your city of birth or your pet's name). This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against credit card fraud and current account fraud, and to contact you should the need arise in administering your account.
We will also require your national insurance number or other commercial and/or identification information if you send or receive certain high-value transactions or high overall payment volumes through PayPal or as is otherwise required in order for us to comply with our anti-money laundering obligations.
Transaction Information
When you use PayPal to send money to someone else or request money from someone else, we ask you to provide information related to each transaction, consisting of the amount of the transaction, the type of transaction (purchase of goods, purchase of services, or simple money transfer ("quasi-cash")) and the e-mail address, Skype ID or phone number of the third party. We retain this information for each of your transactions through PayPal. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to access your PayPal account, in order to help detect possible instances of unauthorised transactions.
Information About You From Third Parties
In order to protect all our customers against potential fraud, we verify the information you provide with bank processors listed in the table under the section “Disclosure to Third Parties Other than PayPal Customers” below. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card with PayPal, we will use card authorisation and fraud screening services to verify that your card information and address match the information that you supplied to PayPal, and that the card has not been reported as lost or stolen.
If you send or receive high overall payment volumes through PayPal, in some circumstances we will conduct a background check on your business by obtaining information about you and your business from a credit bureau or a business information service such as Dun & Bradstreet, as listed in the table under the section entitled, “Disclosure to Third Parties Other than PayPal Customers” below. If you incur a debt to PayPal, we will generally conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. PayPal, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report supplied by such credit bureau for any account, and reserves the right to close an account based on information obtained during this credit review process.
Additional Verification
If we cannot verify the information that you provide, or if you request a withdrawal by cheque to an address other than your verified credit card billing address, we ask you to send us additional information by fax (such as your driving licence, credit card statement, and/or a recent utility bill or other information linking you to the applicable address), or to answer additional questions online to help verify your information.
Website Traffic Information
Because of the way that World Wide Web communication standards work, when you arrive at or leave the PayPal website, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Website you visit while you are on the PayPal site, IP addresses, the type of browser you use and the times you access our Website. We use this information to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with PayPal.
Our Use of "Cookies"
"Cookies" are small files of data that reside on your computer and allow us to recognise you as a PayPal customer if you return to the PayPal site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your PayPal account by entering your email address and password. These cookies allow us to recognise you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.
We also use longer-lasting cookies for other purposes such as to display your email address on our sign-in form, so that you don't have to retype the email address each time when you log in to your PayPal account. We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website.
Customer Service Correspondence
If you send us correspondence, including emails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from PayPal to you. We retain these records in order to keep records of our relationship, to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.
Questionnaires, Surveys and Profile Data
From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.
Non-member Recipients and Requests
When a member either sends a payment to, or requests a payment from, an individual who is not a registered member of PayPal, we will retain the information that the member submits to us, including, for example, the other party's email address, Skype ID, phone number and/or name, for the benefit of the member who is attempting to contact the non-member, so that the member can see a complete record of his or her transactions, including uncompleted transactions. Although this information is stored indefinitely, we will not market to the non-member in any way at any time. Additionally, these non-members have the same rights to access and correct information about themselves (assuming that their detail(s) were correct enough to reach them) as anyone else who uses PayPal.
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Our Use and Disclosure of Information
Internal Uses
We collect, store and process your personal information on servers located in the United States and operated by our parent company, PayPal Inc. Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customised experience. You agree that we may use your personal information to:
- provide the services and customer support you request;
- resolve disputes, collect fees, and troubleshoot problems;
- prevent potentially prohibited or illegal activities, and enforce our User Agreement;
- customise, measure, and improve our services and the content and layout of our website;
- tell you about targeted marketing, service updates, and promotional offers based on your communication preferences;
- compare information for accuracy, and verify it with third parties.
Disclosure to Other PayPal Customers
If you are a registered PayPal user, your name, e-mail address, Skype ID (if applicable), phone number (if applicable) date of sign-up, the number of payments you have received from verified PayPal users and whether you have been verified to have control of a bank account are displayed to other PayPal customers whom you have paid or who are attempting to pay you through PayPal. If you are a Business account holder, we will also display to other PayPal customers the Web site address (URL) and customer service contact information that you provide us. However, your credit card number, bank account and other financial information will NEVER be revealed to anyone whom you have paid or who has paid you through PayPal, except with your express permission or if we are required to do so pursuant to a court order or other legal process.
If you are buying goods or services and pay through PayPal, we may provide the seller with the shipping address for the goods and your confirmed credit card billing address to complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it. To facilitate dispute resolutions, we may provide a buyer with the seller’s address so that goods can be returned to the seller.
We work with third party merchants to enable them to accept payments from you using PayPal. In doing so, a merchant may share information about you with us such as your email address when you are attempting to pay that merchant. We use this information to confirm to that merchant that you are a PayPal customer and that the merchant should enable PayPal as a form of payment for your purchase. Also, if you request that we validate your status as a PayPal customer with a third party, we will do so.
PayPal draws your attention to the fact that some merchants may be established in countries which do not offer the same level of protection as regards data processing as EU member states. By accepting this Privacy Policy, you expressly consent to the exchange of information between PayPal and such merchants as set out above.
By accepting this Privacy Policy, you expressly agree that each time you pay or attempt to pay another PayPal customer or a third party merchant by using your PayPal account, PayPal may then transfer the aforementioned relevant data to the other PayPal customer or to the third party merchant in order to process, execute or otherwise deal and provide information about the payment.
Disclosure to Third Parties Other Than PayPal Customers
PayPal will not sell or rent any of your personally identifiable information to third parties, and will only disclose this information in the limited circumstances and for the purposes described in this policy. This includes transfers of data to non-EU member states where the laws on holding personal data may be less stringent, but as explained below, we will hold and transfer your personal information in compliance with the law and in a manner designed to ensure its security. Specifically, you consent to and direct PayPal to do any and all of the following:
- Disclose information including, without limitation, transaction, account information, personal details and the contents of communications to the police, security forces, competent governmental, intergovernmental or supranational bodies, competent agencies (other than tax related authorities), departments or regulatory, self-regulatory authorities or organisations (including, without limitation, the Agencies set out in the table under the heading “Agencies” below) or other third parties that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity or potential illegal activity, or to conduct investigations of violations of our User Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity's contact information (but not bank account or credit card information without a court order) to victims who request it. Further, if false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies and law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering. Please contact us on the details set out at the end of this privacy policy if you want to receive further details of the relevant fraud prevention agencies. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
- Disclose information in response to requirements of civil or criminal legal process.
- Disclose information to the “Category” of third parties listed in the table below. The purpose of this disclosure is to allow us to provide our service to you. We also set out in the table below, under each “Category”, non-exclusive examples of the actual third parties we currently disclose your account information, together with the purpose of doing so, and the actual information we disclose (these third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information was shared).
| Category |
Party Name and jurisdiction (in brackets) |
Purpose |
Data disclosed |
| Payment processors |
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HSBC Bank Plc (United Kingdom, Ireland), Bank of America (United Kingdom, USA, Italy and India), JPMorgan Chase Bank (United Kingdom, USA), BNP Paribas (France), Netgiro (Sweden), StarFinanz (Germany), Wells Fargo (Ireland, USA), American Express (USA), National Westminster Bank PLC (UK) Australia and New Zealand Banking Group Limited (Australia), ANZ National Bank Limited (New Zealand) and Transaction Network Services (UK) Limited (UK) |
To allow payment processing settlement services, fraud checking. |
Name, address, details of user funding instruments, details of payment transactions |
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Royal Bank of Scotland plc (United Kingdom) (“
RBS”) |
To allow payment processing and dispute handling for transactions of PayPal users when those users transact with a merchant who uses the PayPal service via the RBS service. |
All account information except details of user financial instruments |
| Audit |
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PricewaterhouseCoopers Sàrl (Luxembourg) |
Selection of a sample of individual client accounts to test PayPal’s Anti Money Laundering (AML) & Know Your Customer (KYC) controls. |
Name, PayPal account number (Customer ID), total amount received on the PayPal account, total amount sent from the PayPal account, type of PayPal account, and, as the case may be, any other relevant account information. |
| Customer Service Outsourcing |
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Sutherland Global Services Inc. (USA and Philippines), Sitel GmbH (Germany) and Transcom Worldwide SAS (France, Tunisia) |
Telephone and email customer support services |
Name, address, telephone number, email addresses, truncated funding source information, funding source expiration dates, type of PayPal account, National identity number, account balance and transaction information, customer statements and reports, account correspondence, shipping information, promotional information. |
| Credit Reference Agencies |
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Callcredit plc., Experian Limited and Dun & Bradsheet Limited (United Kingdom), CIFAS (UK), Coface (France), Synectics Solutions Limited (UK), Equifax Ltd (UK), MCL Hunter (UK) |
Verify identity, make decisions concerning a customer’s credit worthiness, carry out checks for the prevention and detection of crime including fraud and/or money laundering, manage PayPal account and undertake statistical analysis, undertake research as to appropriateness of new products and services and system checking. |
Name, address, date of birth, time at address, telephone number, legal form, time in business, company registration number, VAT number (if appropriate) |
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SCHUFA Holding AG (Germany) |
To determine credit worthiness of a merchant using eBay Express in Germany. |
Name, address, date of birth, gender |
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CEG Creditreform Consumer GmbH (Germany) |
To determine credit worthiness of a merchant using eBay Express in Germany. |
Name, address, date of birth |
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Creditreform Berlin Wolfram KG (Germany) |
To determine credit worthiness of a merchant using eBay Express in Germany. |
Name, address |
| Financial Products |
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GE Capital Bank Limited and GE Capital Global Consumer Finance Limited (United Kingdom) |
Joint marketing campaigns for PayPal credit card, risk modelling, enforcement of terms and conditions for PayPal credit card |
Name, address, e-mail |
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Société Générale La Banque Postale and BNP (France) |
Billing purposes |
Only for merchants using PayPal through the partner’s payment solution: merchant ID, number of PayPal transactions and, as the case may be, termination of the PayPal account. |
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Cetelem S.A, Cofidis and Cofinoga S.A. (France) |
Registration of the credit card issued by the credit company on the user’s PayPal account and processing of funding requests made by the same user.
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Name, e-mail address, birth date (as the case may be), credit card number; expiry date, 3 digit Card Security Code (as the case may be) and amount of the funding request and any account information necessary for fraud or dispute resolution. |
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The Royal Bank of Scotland plc (United Kingdom), TYS Card Tech Limited (United Kingdom), TSYS Managed Services EMEA Limited (United Kingdom), TSYS Systems Services inc. (USA). |
Joint marketing campaigns for PayPal prepaid card, risk and fraud modelling, enforcement of terms and conditions for PayPal prepaid card.
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Name, address, e-mail and account information. |
| Commercial Partnerships |
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Royal Mail Group Plc. (United Kingdom) and Pitney Bowes Inc. (USA) |
The provision of automated label printing for sellers using PayPal and eBay to facilitate postal and delivery services, including payment reconciliation services |
Name, address, e-mail, postage transaction amount |
| Marketing and public relations |
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Yesmail Inc. (USA) |
Fulfilment of e-mail marketing programs of PayPal services and promotions. |
Name, e-mail, address, business name, domain name, account status, account preferences, type and nature of PayPal services offered or used. |
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UCN (USA) and Decipher Inc. (USA) |
Execution of customer service surveys |
Name, e-mail address, type of account, type and nature of PayPal services offered or used and relevant transaction information. |
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Adwise (France) and Axance (France) |
Execution of marketing surveys |
Name, e-mail address, telephone number, type of account, type and nature of PayPal services offered or used and relevant transaction information.
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BD Network Limited and Tullo Marshall Warren Limited (United Kingdom), MyCash (France) |
Development and execution of customer promotions |
Name, address, e-mail |
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Salesforce.com (USA) |
Storage of merchant contact information |
Name, address, telephone number, email |
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Noesis srl (Italy), Lansons Communications (United Kingdom) Text 100 (Spain and Netherlands) and I&E Consultants (France) |
Response to media enquiries regarding customer queries |
Name, address, customer account information relevant to customer queries |
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Alchemy Worx Ltd (UK). |
To allow management reporting of marketing campaigns. |
Name, email address, details of customer campaign interaction. |
| Operational services |
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KSP Kanzlei Dr. Seegers, Dr. Frankenheim & Partner Lawyers (Germany), NCO Collections Europe Limited, Robinson Way, Intrum Justitia Limited (United Kingdom), IQOR Recovery Services Limited (UK) |
Debt collection |
Name, address, telephone number, account number, e-mail, account type, last four digits of financial instruments account, account balance, details of account transactions and liabilities. |
| Group companies |
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PayPal Inc. (USA) |
Acting on behalf of PayPal or the purposes of storing and processing of account information |
All account information |
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PayPal Europe Services Limited (Ireland) and eBay Europe Services Limited |
Acting on behalf of PayPal for the purpose of customer support, compliance and other back office |
All account information |
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PayPal Private Limited (Singapore) |
Acting on behalf of PayPal to enter into and perform non-customer contracts which involve customer data |
All account information |
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eBay Inc. (USA), eBay Europe S.à.r.l. (Luxembourg), eBay International AG (Switzerland), eBay CS Vancouver Inc. (Canada), Skype Communications SA (Luxembourg), Skype Inc. (USA), Skype Software SA (Luxembourg), GumTree.com Limited (UK), Kijiji International Limited (Ireland), Shopping.com Inc. (USA), Shopping Epinions International Limited (Ireland), PayPal Australia Pty Limited, Marktplaats B.V (Netherlands) |
provide joint content and services (like registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of policies, and to guide decisions about their products, services and communications (not acting as a sub-contractor of PayPal) |
All account information |
| Agencies |
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CSSF (Luxembourg) Financial Ombudsman Service (United Kingdom), Altroconsumo (Italy), European Consumer Centre network organisations located in Austria, Belgium, Czech republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, The Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden; Les Mediateurs du Net (France), BaFin (Germany) |
To request information within their authority and to respond to queries and/or investigations instigated by users or other stakeholders in the countries they have jurisdiction. |
All account information |
For the purpose of this table, the phrase “All account information” includes: name, address, e-mail, telephone number, account number, account type, details of funding instruments associated with the account, details of payment transactions, details of commercial transactions, customer statements and reports, account preferences, and customer correspondence
With respect to the column titled, “Purpose”, each third party, with the exception of the regulatory agencies and group companies referred to at the end of this table, is carrying out the purpose to fulfil obligations which PayPal has contracted with the entity to fulfil. The regulatory agencies are carrying out their purpose in accordance with their regulatory objectives and requirements.
- Disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
- Disclose aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in Manchester. However, this aggregated information is not tied to personal information.
- As with any other business, it is possible that PayPal in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by PayPal, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended.
Our Contacts with PayPal Customers
We communicate with users on a regular basis via email to provide requested services, and we also communicate by phone to resolve customer complaints or claims made by users via PayPal, respond to requests for customer service, inform you if we believe your account or any of your transactions have been used for an illegitimate purpose, conduct customer surveys or investigate suspicious transactions. We use your email address to confirm your opening of a PayPal account, to send you notice of payments that you send or receive through PayPal (including referral payments described below), to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.
We also use your email address to send you other types of communications that you can control, including the PayPal Periodical newsletter, auction tips, customer surveys and notice of special third-party promotions. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the PayPal website and changing your preferences in the Profile page of the My Account tab. You can also change your choices at any time through the same procedure.
In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.
Your Use of Information and Our Services
In order to facilitate the transactions between PayPal members, our service allows you limited access other users' contact or delivery information. As a seller you may have access to the User ID, email address and other contact or delivery information of the purchaser, and as a purchaser you may have access to the User ID, email address and other contact information of the seller.
By entering into our User Agreement, you agree that, with respect to other users' personally identifiable information that you obtain through the site or through a PayPal-related communication or PayPal-facilitated transaction, you will only use this information for: (a) PayPal-related communications that are not unsolicited commercial messages, (b) using services offered through PayPal (e.g. insurance, delivery and fraud complaints), and (c) any other purpose that such user expressly agrees to after adequate disclosure of the purpose(s).
In all cases, you must provide users with the opportunity to remove themselves from your database and review any information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another PayPal user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel and other rights holders are given different rights with respect to information they access.
PayPal does not tolerate spam. Therefore, without limiting the foregoing, you may not add a PayPal user to your marketing mail list (email or physical mail) without their express consent after adequate disclosure, even if said user has previously made a purchase from you. We strictly enforce our Anti-Spam Policy To report PayPal-related spam to PayPal, please contact us.
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Information Security
PayPal is committed to handling your customer information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfil their job responsibilities.
For more information on PayPal's security practices, please visit the PayPal Security Centre.
The security of your PayPal account also relies on your protection of your PayPal password. You may not share your PayPal password with anyone. PayPal representatives will never ask you for your password, so any email or other communication requesting your password should be treated as unauthorised and suspicious and forwarded to spoof@paypal.com. If you do share your PayPal password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings, and also contact us right away as described below.
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Accessing and Changing Your Information
You can review the personal information you provided us and make any desired changes to such information, or to the settings for your PayPal account, at any time by logging in to your account on the PayPal website and changing your preferences in the Profile page of the "My Account" tab. You can also close your account through the PayPal website. If you close your PayPal account, we will mark your account in our database as "Closed," but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.
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Accountability
Our privacy office is responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you have any questions about this privacy statement, PayPal's information practices, or your dealings with PayPal, you can contact us using this form, call the customer service number located on our Website or write us at PayPal (Europe) S.à r.l. & Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg.
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