Sprinque Finance B.V. Merchant Privacy Statement
This merchant privacy statement is applicable to the processing of personal data of merchants by Sprinque Finance B.V. (Sprinque Finance). In connection with Pay by Invoice, Sprinque B.V. assigns its receivables against end-customers in connection with their purchases from merchants (the End Customer Receivables) to Sprinque Finance. Sprinque B.V. also assigns to Sprinque Finance its associated receivables against merchants in relation to fees and if applicable foreign exchange amounts (the Merchant Receivables). In connection herewith, Sprinque B.V. shares the names and address details of the merchant to which the End Customer Receivables and the Merchant Receivables relate (together the Receivables) with Sprinque Finance.
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This merchant privacy statement is meant for persons whose personal data are provided to Sprinque Finance in connection with the assignment of the Receivables as described above. Data relating to a company under certain circumstances qualify as personal data. This is the case in the event of small companies with a sole or few proprietor(s) and/or name giver(s). Data in relation to contact persons and representatives of a company also qualify as personal data.
In this merchant privacy statement, Sprinque B.V. and Sprinque Finance inform you about the use of your personal data. They are required to do so under the General Data Protection Regulation (GDPR). The transfer of your personal data to Sprinque Finance has no material implications for you. The administration of the Receivables is still managed by Sprinque B.V. on behalf of Sprinque Finance.
Joint responsibility
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Sprinque B.V. and Sprinque Finance are jointly responsible for processing your personal data.
Sprinque B.V.'s registered office is at Prinsengracht 526-H, 1017 KJ Amsterdam, the Netherlands, Chamber of Commerce 81977050. Sprinque Finance's registered office is at De Lairessestraat 145 A, 1075 HJ Amsterdam, the Netherlands, Chamber of Commerce 89647319.
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Sprinque B.V. and Sprinque Finance have entered into an agreement covering their joint responsibility under the GDPR. You can request more information about this by sending an email to legal@sprinque.com. Sprinque B.V. is the main point of contact regarding the data processing
activities described in this merchant privacy statement. For questions or comments about the
processing of your personal data by Sprinque B.V. and Sprinque Finance, you can contact Sprinque B.V. via legal@sprinque.com.
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Purposes of the data processing
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Sprinque Finance is the creditor of the Receivables and processes your personal data in that context. In addition, Sprinque Finance may request Sprinque to provide data in relation to ultimate beneficial owners, directors and representatives of a merchant to comply with statutory sanction regulations. These data will then be processed by its management, Trustmoore Netherlands B.V.
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Sprinque B.V. however manages the complete administration of Sprinque B.V. In this context,
Sprinque B.V. processes the name and address details of the merchant (which in some circumstances qualify as personal data) and fees and if applicable foreign exchange amounts due. Sprinque Finance, as a creditor, may independently dispose of the Receivables and may, for example, pledge the Receivables to third parties. In such case, your data may also be provided to those third parties insofar necessary to, for example, collect pledged Receivables. Sprinque Finance may also retransfer the Receivables to Sprinque B.V. or transfer them to a third party for collection purposes, or outsource the debt collection to another party than Sprinque B.V., for example if you fail to meet your payment obligations.
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Based on its legitimate interests, Sprinque Finance may decide to outsource the administration of the Receivables to a third party other than Sprinque B.V. Sprinque B.V. is then no longer jointly responsible for the processing of your personal data. If this situation arises, Sprinque Finance will inform you accordingly.
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Sprinque B.V. and Sprinque Finance also process your data if necessary to establish, exercise or
defend their rights or to comply with legal obligations.
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Payments to and by Stichting Sprinque
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Sprinque Finance has outsourced the receipt of the merchant’s payments to Stichting Sprinque. Sprinque B.V. has outsourced the making of payments intended for the merchant to Sprinque Finance, who has in turn outsourced the making of those payments to Stichting Sprinque. This means that your name, address, place of residence, IBAN and amounts due can in some cases also be processed by Stichting Sprinque and its management, Trustmoore Netherlands B.V. For the processing of these data, Stichting Sprinque and its management, Trustmoore Netherlands B.V. are independently responsible. Stichting Sprinque is established in the Netherlands. Sprinque B.V. is the point of contact for the processing of your personal data by Stichting Sprinque and you can contact Sprinque B.V. via legal@sprinque.com.
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Legal basis
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The basis for the processing of your personal data by Sprinque B.V., Sprinque Finance and Stichting Sprinque is the legitimate interest of Sprinque Finance to properly collect payment of the Receivables, to otherwise enforce or sell Receivables and to determine and defend its legal position. In addition, the processing of your personal data is necessary to comply with legal obligations, such as statutory sanction regulations and the obligation to keep your personal data for certain legal retention periods.
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Third parties
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Sprinque B.V., Sprinque Finance and Stichting Sprinque will disclose your personal data to third
parties, in the following cases:
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to service providers, such as accountants or debt collection agencies, for the purposes mentioned above;
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to third parties to whom the Receivables have been assigned, transferred or pledged. In such cases, these parties will only receive personal data insofar necessary to dispose of the Receivables, manage the payment obligations and the collections of payments;
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where there is a statutory duty to share the data;
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if Sprinque Finance requests Sprinque to provide data in relation to ultimate beneficial owners, directors and representatives of a merchant to comply with statutory sanction regulations, these data will be processed by its management, Trustmoore Netherlands B.V.;
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in the cases mentioned under ‘Payments to and by Stichting Sprinque’: the data mentioned are visible to the management of Stichting Sprinque, Trustmoore Netherlands B.V.;
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to third parties acting as processors on behalf of Sprinque B.V., Sprinque Finance or Stichting Sprinque within the meaning of the GDPR; or
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with your consent or otherwise in accordance with the GDPR.
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Sprinque B.V., Sprinque Finance and Stichting Sprinque will not provide your personal data to third parties located outside the EEA without an adequate protection level of personal data.
Retention period
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Your personal data will be stored for no longer than is necessary for the purposes mentioned above. This means your personal data will in general be stored for 2 years after the Receivables have been paid and longer where necessary to comply with statutory requirements.
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Your rights
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You have the right to request access to your personal information and, under certain circumstances, to have your personal data corrected, deleted and/or blocked. You can also request that the processing of your personal data be restricted and you can request a machine-readable version of your personal data for storage elsewhere.
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You also have the right to object to your personal data being processed in connection with your
personal circumstances which outweigh the legitimate interests of the parties responsible for your processing as set out above.
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You can file a complaint with the Dutch Data Protection Authority about how your personal data are processed at any time via https://autoriteitpersoonsgegevens.nl/.
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Contact
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If you wish to exercise any of the above rights or if anything is unclear, please contact
Dated: 1 May 2023