Subcontractors

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In providing its payment services, Centralpay relies on a number of processors as defined in Article 4 of the General Data Protection Regulation (GDPR). These processors may be required to process personal data on behalf of Centralpay, exclusively in accordance with documented instructions and within the scope of the purposes of the service to which they contribute.

This page lists the subcontractors that may be involved in the processing of personal data belonging to Account Owners, Merchants, and Payers who use Centralpay services. It is updated as our system evolves.

Subcontractor	Purpose	Country Where Data Is Processed	Data Categories
Amazon Web Services (AWS)	Cloud hosting for certain services and application data	Ireland	All data processed by the departments
Comply Advantage (IVXS)	AML/CFT Screening and Verification Against International Sanctions Lists	Romania	Identification Information
Dotfile	Management of onboarding processes, collection and updating of KYC/KYB records	France	Identification Information, Supporting Documents
Gpayments	3D Secure authentication for Card Transactions (second service provider)	Ireland	Card data, authentication
Innovest	The group’s parent company; internal recipient for the purposes of governance, audit, compliance, and consolidated reporting	France	Governance and Reporting Data
Microsoft	Management and Control of Cash Flows	France	Transaction and Accounting Data
Netcetera	3D-Secure Authentication for Card Transactions (Access Control Server)	Switzerland	Card data, authentication
Onfido	Automated verification of identification documents and biometric data (facial recognition, liveness detection)	Europe	Identification data, biometric data
Qombo	Verification of Beneficiary (verification of the beneficiary of a SEPA bank transfer)	France	Identification Information, IBAN
Tanla Digital Labs	Sending text messages (authentication codes, notifications)	Europe	Phone number, message content

Supervision of Subcontractors and Change Control Procedures

In accordance with Article 28 of the GDPR, all processors engaged by Centralpay act exclusively on the basis of documented instructions, are bound by strict contractual obligations regarding confidentiality and security, and may not use personal data for any purposes other than those defined by Centralpay.

Any substantial change to this list will be announced in advance by any appropriate means (notification on the Merchant Portal, email, or a public update to this page), allowing the individuals concerned, if applicable, to object to such changes.

If you have any questions regarding the processing of your data or the exercise of your rights, you can contact our Data Protection Officer at: dpo@centralpay.eu.

Subcontractors

Supervision of Subcontractors and Change Control Procedures

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