Privacy policy

This Privacy Policy was last modified and is effective as of 27/11/2023.

This Policy applies to the processing of your personal data, as well as the use of "cookie" files and similar technologies on the website (the “Website).

Nethone sp. z o.o. with its registered office at Plac Europejski 1, 00-844 Warsaw, Poland (“Nethone”) acts as a joint controller together with the following entities:

  • AI Stargate (Luxembourg) S.à.r.l., registered at 2 Avenue Amélie, L-1125 Luxembourg ("AI Stargate")
  • Mangopay S.A., registered at 2 Avenue Amélie, L-1125 Luxembourg ("Mangopay S.A.")
  • Mangopay UK Limited, registered at The Smiths Building, 179 Great Portland St, London W1W 5PL ("Mangopay UK")
Jointly referred to as "Group Companies", “We”, “Our”.

Your Privacy is important to us!

We recognize that your privacy is very important to you and that it is your right to control and be informed about the information we process about you and how we process it. We know that providing personal data is an act of trust and we take that trust seriously. We will never sell, rent, or otherwise disclose your personal data, except as outlined in the Privacy and Cookie Policy, provided that we have an appropriate legal basis for such disclosure. 

By registering for the free trial of our solution or committing for our paid Services, you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. This Privacy Policy forms part of and should be read in conjunction with our Terms and Conditions as applicable for the model of Services offered (be it for our free trial, available here or as appended to the SaaS agreement regarding our paid Services).

1. Categories of personal data

Conclusion and performance of the Terms and Conditions involve personal data processing (name, surname, job title, corporate e-mail address) of natural persons (your proxies, representatives, employees, contractors, etc.) transferred by the Client to Nethone. This can include personal data of the Client himself/herself when a Client is a natural person. We process your personal data provided at the point of registration (name, surname, e-mail address) for the purpose of enabling your user access to our services. 

Insofar as the performance of the Terms and Conditions involves the processing of personal data of Client’s representatives, employees, contractors, etc., the Client acknowledges that this Privacy Policy is applicable to such processing and undertakes to provide such representatives, employees, contractors, etc. with its content.

2. Purposes and legal basis

The processing of such data by Nethone and the joint controllers is necessary for the purpose of managing our client relationship, concluding and performing the Terms and Conditions (including contacting for marketing purposes, unless Nethone receives an objection to such processing), as well as exercising all the rights and obligations relating to the performance of the Terms and Conditions.

In processing your data, we pursue our legitimate interest in (i) direct marketing of our services, (ii) enabling the provision of our services based on the Terms and Conditions, (iii) exercising our contractual and legal rights and obligations. If the Client is a natural person, we process the personal data based on the contract, i.e. the processing is necessary for the conclusion and performance of the contract, to which the data subject is a party.

Provision of personal data is voluntary, but if you don’t provide us with the basic personal data, we will not be able to conclude the Terms and Conditions with the Client or contact the Client in connection with the provision of services pursuant to the Terms and Conditions.

3. Your rights

You have the right to object to the processing of your data by us and to request that we correct or delete your data. If you file such a request we will stop processing your data and delete it, unless there exists an important overriding legal interest (e.g. defense of claims or existence of a legal obligation to retain the data) that will entitle us to keep your data for a longer period. You also have the right of access to your data, as well as the right to data portability and to restriction of the processing.

4. Retention periods 

We process your personal data only for as long as necessary for the purposes, for which it was collected. As a general rule, we will process personal data for as long as we have a contractual relationship with the Client and/or for as long as you remain the contact person or employee/contractor of the Client, whichever is the earliest. We will also process the data after the termination of the contractual relationship, for the duration of the statutory period of 3 years. We may have to process personal data for a longer period of time in limited circumstances, i.e. in case we need to defend against legal claims.

5. Sharing your personal data with third parties

We entrust the processing of your personal data to entities, which act on our behalf and solely based on our instructions (data processors). In particular, we use data processors, whom we select carefully, to store your data on secure servers located within the territory of the EU. In the event that personal data is entrusted for further processing to subprocessors outside the EEA, we ensure that appropriate safeguards (in particular Standard Contractual Clauses) are in place to ensure the legality of such transfer and the security of your data.

We may have to share your personal data with competent authorities (in particular the police or prosecution service), if they approach us with such a request, provided that there exists an appropriate legal basis for making your personal data available to them (e.g. a court order).

6. Responsibilities of joint controllers

As joint controllers, Group Companies jointly determined their respective responsibilities for compliance with data protection obligations. In particular, the Group Companies have decided that Mangopay S.A. and Nethone, as the case may be, are responsible for:

  • fulfilling information obligations on behalf of joint controllers;
  • ensuring legal basis for data transfers outside the European Economic Area (EEA), should Group Companies decide to entrust the processing of data to entities located in a third country;
  • conclusion of data processing agreements when data are entrusted to processors;
  • acting as a common point of contact for individuals whose data are processed. 
All the other obligations remain with individual Group Companies as data controllers. 

7. Contact

If you have any questions with regard to the processing of your data by us or if you wish to exercise your rights, you can contact our data protection officer, Michał Madej, at or any of our joint controllers at You also have the right to file a complaint to the data protection authority.

8. Modification of the Policy

We may periodically be required to make changes to our Privacy Policy (for example if we substantially change the way our Services or the Website functions, or following legislative changes). We will notify you of these changes by posting the modified Privacy Policy on the Website. If the changes are substantial, we will also notify you by e-mail. We recommend that you revisit this Privacy Policy regularly. You may determine when this Privacy Policy was last updated by referring to the date found at the top of the first page of this Privacy Policy.

Our use of cookies and similar technologies

1. In order to improve the operation of our site, we use cookies, web beacons, device fingerprinting, and similar technologies. We can also make use of Google Analytics tools.

2. Cookies are text files containing small amounts of information that are downloaded to your personal computer, mobile, or another device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. The following types of cookies are used on the Website:

  • Persistent cookies - these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
  • Session cookies - these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
  • Strictly necessary cookies - These cookies enable services you have specifically asked for. For those types of cookies that are strictly necessary, no consent is required. These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
  • Performance cookies - These cookies collect anonymous information on the pages visited. By using the Website, you agree that we can place these types of cookies on your device. These cookies collect information about how visitors use the Website, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.
  • Functionality cookies - These cookies remember choices you make to improve your experience. By using the Website, you agree that we can place these types of cookies on your device. These cookies allow the Website to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts, and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
  • Targeting or advertising cookies - These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

3. Web beacons (also known as pixel tags) are transparent image files used to monitor your journey around and interact with the Website and its content.

4. Device fingerprinting is a technology that allows us to collect information about your device (what browser or operating system you use, plug-ins, time zone, other settings). We use this information to identify you and to ensure the security of our website.

4. Google Analytics & Firebase is a tool we use in order to calculate visits to our website, check which functionalities of our website are used most and improve the operation of the Website. If you wish to learn more about Google Analytics tools and your privacy, please visit the following site: You can also opt-out from Google Analytics by installing a browser add-on available here:

6. Mobile Analitycs is a software we use to better understand the functionality of our mobile software on your phone. This software may record information such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application. Link to the privacy policy of third-party service providers used by the app:

7. Cookies and similar technologies are used for statistical purposes, to adapt the website content, performance, and structure to users’ individual preferences, to provide users with advertising content adapted to their preferences. Cookies and web beacons for ads targeting purposes can be linked to other online services, such as Facebook. Please note that cookies may collect personal information to enhance the site's functionality. Such data is stored in encrypted form and access to them is limited. Cookies that are used by third parties via the Website, including in particular the users of the website, are subject to their own privacy policy.

8. Handling and use of "cookies" and similar technologies is allowed automatically. However, these settings can be changed at any time. For details on how cookies are handled and used, see the settings of your web browser. You can learn more about cookies and similar technologies and check how to disable them for the browser you use by visiting the following website:

9. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application. For the above purposes, we may require that you share with us the following information:

10. We also collect certain online identifiers, such as device technical information, online identifiers, IP address, location, and information on interaction with the website, for the purpose of fraud prevention. The legal basis pursued is our legitimate interest in preventing fraud and account takeover.