List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
To allow payment
Name, address,
processing
details of user funding
settlement
instruments, and
services, and fraud
details of payment
checking.
transactions
1. Payment Processors
HSBC Bank Plc (UK, Ireland), HSBC Merchant
Services LLP (UK), Bank of America (UK, USA,
Italy, and India), Discover Financial Services
(USA), JPMorgan Chase Bank (UK, USA), BNP
Paribas (France), Netgiro (Sweden), StarFinanz
(Germany), Wells Fargo (Ireland, USA),
American Express (USA), National Westminster
Bank PLC (UK), OmniPay Limited (Ireland),
Australia and New Zealand Banking Group
Limited (Australia), ANZ National Bank Limited
(New Zealand) and Transaction Network
Services (UK) Limited (UK)
To allow the
processing of
Deutsche Bank AG (Germany, Netherlands,
direct debits in
France, Spain)
Germany,
Netherlands,
France and Spain.
Name, date of
transaction, amount,
currency and user’s
bank account
information.
To allow payment
processing and
dispute handling
for transactions of
Royal Bank of Scotland plc (UK) (“RBS”)
PayPal users when
All account information
those users
except details of user
transact with a
financial instruments.
merchant who
uses the PayPal
service via the
RBS service.
Visa Europe Ltd (UK) including Visa’s VMAS
To share risk and
All account details of
1
© 2015 PayPal. All rights reserved.
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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
system; Mastercard International Incorporated.
fraud information in
merchant account, and
(USA) including Mastercard’s MATCH system
the mandatory
circumstances and
credit card
conduct of the account
company’s
database regarding
the conduct of a
merchant’s
account thereby
reducing exposure
to fraud and
breaches of
scheme rules and
standards.
To allow payment
processing, fraud
checking and
dispute handling
Global Payments UK LLP (UK)
for transactions of
Name, address,
PayPal users when
details of user funding
those users
instruments and
transact with a
details of payment
merchant who
transactions
uses the PayPal
service via the
Global Payments
service.
To allow payment
processing, fraud
WorldPay (UK) Limited, Worldpay AP Limited,
checking and
dispute handling
(UK) Worldpay . (The Netherlands)
for transactions of
All Account
information except
details of user financial
instruments
PayPal users when
those users
2
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
transact with a
merchant who
uses the PayPal
service via
Worldpay service.
Unique Seller ID.
Seller MCC
Seller DBA
Authorized signer
Seller address, postal
and country code
Seller phone number
Seller email address
Seller URL
Date of birth (for sole
proprietors only)
To allow payment
American Express Travel Related Services
processing
settlement
Company, Inc.
services, and fraud
checking.
For non-publicly
traded Sponsored
Merchants only (e.g.
privately held
company, sole
proprietor), the
following information
for a Significant Owner
(as defined below):

First and last
name

Home
address,
postal code
and country
code

SSN or date of
3
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
birth
Significant owner
means an individual
who has 25% or
greater ownership of a
business.
Unique seller ID*
Sponsored Merchant
MCC
Sponsored Merchant
DBA
Sponsored Merchant
location (city, street,
postal code and
country code)
Sponsored Merchant
phone number
Anti-money
JPMorgan Chase Bank, N.A. London Branch
laundering,
Name of merchant,
sanctions list
country of domicile,
checking and
and business activity
compliance checks
To allow payment
processing and
Adyen B.V. (Netherlands)
settlement services
globally.
To allow payment
processing and
settlement services
in Europe.
Allied Irish Bank PLC (UK)
Name, address,
details of payment
instruments, and
details of payment
transactions.
Name, address,
details of payment
instruments, and
details of payment
transactions.
4
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
To facilitate
3DSecure
Cardinal Commerce Corporation (US)
checking for
Standard transaction
payment
data for 3DSecure.
processing
globally.
To allow payment
processing and
Coinbase Inc. (US)
settlement services
globally.
Heartland Payment Systems, Inc. (USA)
Merchant e-Solutions, Inc. (US)
details of payment
transactions.
processing and
details of payment
settlement services
instruments, and
in the United
details of payment
States.
transactions.
To allow payment
Name, address,
processing and
details of payment
settlement services
instruments, and
in the United
details of payment
States.
transactions.
processing and
settlement services
To allow payment
processing and
settlement services
in Australia.
Network Merchants, LLC. (US); Network
instruments, and
Name, address,
in Canada.
National Australia Bank Ltd. (Australia)
details of payment
To allow payment
To allow payment
Moneris Solutions Corporation (Canada)
Name, address,
To allow payment
Name, address,
details of payment
instruments, and
details of payment
transactions.
Name, address,
details of payment
instruments, and
details of payment
transactions.
Name, address,
5
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
Merchants Inc. (US)
processing and
details of payment
settlement services
instruments, and
in the United
details of payment
States.
transactions.
To allow payment
Stockholms Enskilda Bank AB (Sweden)
processing and
settlement services
in Europe.
To allow payment
WorldPay, Inc. (US); WorldPay Ltd. (UK)
processing and
settlement services
globally.
Processing
payments to allow
Carta Worldwide (UK)
PayPal to operate
with third party
products like the
Vodafone Wallet.
Name, address,
details of payment
instruments, and
details of payment
transactions
Name, address,
details of payment
instruments, and
details of payment
transactions.
First, Last Name,
Billing Address
(Street Name,
House Number,
City, State,
Postal Code,
Country), Payer
ID, Given
Payment
Method, CMID /
Client Metadata
ID, e-mail.
2. Audit
PricewaterhouseCoopers Sàrl (Luxembourg)
To test PayPal’s
For a sample of
Anti Money
individual customer
Laundering (AML)
accounts:
and Know Your
name, PayPal account
Customer (KYC)
number (Customer
6
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
controls and to
ID), total amount
carry out
received on the
professional
PayPal account, total
auditing services
amount sent from the
for PayPal Inc. and
PayPal account, type
its subsidiaries.
of PayPal account,
and, as the case may
be, any other relevant
account information.
3. Customer Service Outsourcing
Name, address, phone
number, email
addresses, truncated
and limited or full
funding source
information (case
Sutherland Global Services Inc. (USA and
dependent), funding
Philippines), Sitel GmbH (Germany), Transcom
Worldwide SAS (France, Tunisia), Transcom
Worldwide France SAS (France), Transcom
Worldwide SpA (Italy), Competence Call Center
Leipzig GmbH (Germany), Convergys Customer
source expiration
To allow telephone
dates, type of PayPal
and email
account, proof of
customer support
identity, account
services.
balance and
Management Group Inc. (USA), Arvato Direct
transaction
Services GmbH (Germany) and Concentrix
information, customer
Europe Limited (UK)
statements and
reports, account
correspondence,
shipping information,
and promotional
information.
Nuance Communications Inc. (USA)
To calibrate and
Recordings of a
optimise speech
sample of customer
7
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
recognition
support telephone
performance for
calls, which may
telephone
include any or all
customer support
account information
services.
transmitted during the
call.
ICT Group Inc. (US)
To perform and
Name, address, phone
facilitate telephone
number, and PayPal
customer support.
account number.
Information provided
by the customer via
social media channels
which may include
name, address, phone
number, email
addresses, social
media user names,
truncated and limited
Lithium Technologies Inc. (USA)
To provide
or full funding source
customer services
information (case
arising from
dependent), funding
customer contacts
source expiration
to PayPal on social
dates, type of PayPal
media channels.
account, proof of
identity, account
balance and
transaction
information, customer
statements and
reports, account
correspondence,
shipping information
and promotional
8
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
information.
Information provided
by the customer via
social media channels
which may include
name, address, phone
number, email
addresses, social
media user names,
truncated and limited
To provide
customer services
arising from
Attensity Europe GmbH
customer contacts
to PayPal on social
media channels.
or full funding source
information (case
dependent), funding
source expiration
dates, type of PayPal
account, proof of
identity, account
balance and
transaction
information, customer
statements and
reports, account
correspondence,
shipping information,
and promotional
information.
To provide
webinars (online
ILinc Communications, Inc. (USA)
seminars) to
Name, email address
of merchants
merchants on
ILinc’s platform.
ePerformax Contact Centers & BPO (USA),
To provide
Name, address, phone
9
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
Genpact International Inc. (USA), LatentView
customer services
number, email
Analytics Pte. Ltd
regarding
addresses, truncated
payments globally.
and limited or full
funding source
information (case
dependent), funding
source expiration
dates, type of PayPal
account, proof of
identity, account
balance and
transaction
information, customer
statements and
reports, account
correspondence,
shipping information,
and promotional
information.
Telephony based
Authentify Inc.
authentication
service
Mobile and land-line
phone numbers
Name, email address,
PayPal transaction ID,
return information
(returned item
CallPoint New Europe AD dba TELUS
To operate
category, reason for
International Europe (Bulgaria)
refunded returns
return, amount of
service.
return, currency,
country of return, type
of return) and shipping
documentation
evidence.
10
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
First name, last name,
Key Performance Group SAS, France
Administration of
email, customer ID,
PayPal member
transaction information
referral program
related to referral
rewards
To provide
analytics allowing
New Relic, Inc. (US)
us to troubleshoot
errors in the
service globally.
Log Data and
Aggregated data on
the service
performance.
To alert on-call
PagerDuty, Inc. (US)
technicians that an
Subject of the Email at
email has arrived
issue.
globally.
To provide
analytics allowing
Sumologic, Inc. (US)
us to troubleshoot
errors in the
service globally.
Log Data and
Aggregated data on
the service
performance.
4. Credit Reference and Fraud Agencies
Please note that in addition to the stated purposes below, PayPal uses your personal information to
detect, prevent, and/or remediate fraud or other illegal actions, or to detect, prevent or remediate
violations of policies or applicable user agreements.
CRIF (Italy), Cerved B.I (Italy), Coface (France),
To verify identity,
Name, address, phone
Synectics Solutions Limited (UK), MCL Hunter
verify linkage
number, email
(UK), GB Group plc (UK), Graydon (UK), Capita
between a
address, date of birth,
Plc (UK),UK Data Limited (UK), ICC Information
customer and its
length of time at
Limited (UK), Payment Trust Limited (UK),
bank account or
address, proof of
192.com (UK), 192.com Limited (UK), i-CD
credit/debit card,
identity, legal form,
Publishing (UK) Limited (UK), Experian
assist in making
length of time in
Netherlands BV (Netherlands), Experian Bureau
decisions
business, company
de Credito SA (Spain), Informa D&B SA (Spain),
concerning a
registration number,
11
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
and CRIBIS D&B S.r.l. (Italy).
customer’s credit
VAT number, funding
worthiness
instrument including
(including without
bank account and
limitation, in
credit /debit card
relation to credit
details (if appropriate)
products offered by and relevant
PayPal), carry out
transaction information
checks for the
(if appropriate).
prevention and
detection of crime
including fraud
and/or money
laundering, assist
in debt recovery,
manage PayPal
accounts and
undertake
statistical analysis,
undertake research
and testing as to
appropriateness of
new products and
services and
system checking.
Please note that
data disclosed to
these agencies
may be retained by
the applicable
credit reference
and fraud agency
for audit and fraud
12
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
prevention
purposes.
To verify identity,
verify linkage
Name, address, phone
between a
number, email
customer and its
address, date of birth,
bank account or
length of time at
credit/debit card,
address, proof of
make decisions
identity, legal form,
concerning a
length of time in
customer’s credit
business, company
worthiness
registration number,
(including without
VAT number, funding
Callcredit plc. (UK) including the SHARE
limitation, in
instrument including
database administered by Callcredit, Experian
relation to credit
bank account and
Limited (UK) including databases administered
products offered by credit /debit card
by Experian used for consumer and commercial
PayPal), carry out
details (if appropriate),
referencing including CAPS credit searches and
checks for the
relevant transaction
CAIS credit account performance data, Equifax
prevention and
information (if
Ltd (UK) including the Insight database
detection of crime
appropriate), account
administered by Equifax, Dun & Bradstreet
including fraud
balance, all
Limited (UK)
and/or money
information supplied
laundering, assist
and used for your
in debt recovery,
application for the UK
manage PayPal
products “Website
accounts and
Payments Pro”,
undertake
“Virtual Terminal” and
statistical analysis,
“PayPal Here” and the
undertake research financial instrument
and testing as to
used to pay for your
appropriateness of
PayPal Here- enabled
new products and
device.
services and
13
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
system checking.
For users of the
UK products
“Website
Payments Pro”,
“Virtual Terminal”
and “PayPal Here”
and UK merchants
only:
• to report defaults
and supply monthly
account
performance
information, where
the account shows
an amount owing
to us (reflected as
a negative
balance) for three
or more
consecutive
months, to the
databases of these
third parties; and
• for the purposes
set out in section 8
of this Privacy
Policy.
Please note that
data disclosed to
these agencies
14
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
and databases
may be:
• retained by the
applicable credit
reference agency
or database for
audit and fraud
prevention
purposes;
• disclosed to other
financial
institutions for the
purpose of gauging
creditworthiness;
and
• transferred
outside of the EU
and on a global
basis.
For users with UK
PayPal accounts
only: to prevent
and detect fraud
(which may include
checking details on
CIFAS (UK) and the CIFAS database
job applicants and
employees and on
All account details and
circumstances of the
conduct of the account
proposals and
claims for all types
of insurance).
Please note that
data disclosed to
15
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
this database may
be:
• retained by the
database for audit
and fraud
prevention
purposes;
• disclosed to other
financial
institutions for the
purpose of fraud
prevention and
detection (including
to prevent money
laundering) for
example, when
checking details on
applications for
credit and other
facilities, managing
credit and credit
related accounts or
facilities,
recovering debt,
checking details on
claims for
insurance and
checking details of
job applicants or
employees;
• used to
determine your risk
16
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
profile and for
cooperation with
the relevant
authorities in
compliance with
the requirements of
the Luxembourg
Law of 5 April 1993
on the financial
sector and laws
relating to the
prevention of
money laundering,
terrorism and fraud
(excluding the
treatment of
personal data in
relation to solvency
of the persons
referred to in article
14(1)(d) of the
Luxembourg Law
of 5 April 1993 on
the financial
sector); and
• transferred
outside of the EU
and on a global
basis.
DueDil Limited (UK)
To receive
Company registration
business
number, name and
information for risk
address of business,
assessment, and
name, address, date
17
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
compliance with
of birth of directors.
anti-money
laundering
requirements, such
as establishing the
corporate structure
and beneficial
ownership.
To receive
business
information for risk
assessment, and
compliance with
Creditsafe USA Inc. (USA), Creditsafe UK
anti-money
laundering
requirements, such
Company registration
number, name, and
address of business,
name, address, date
of birth of directors
as establishing the
corporate structure
and beneficial
ownership.
Establish risk
associated with
address, identity;
assist in making
decisions
concerning a
customer’s credit
Deltavista GmbH (Germany)
Name, address, date
of birth, email address
worthiness;
research and
testing as to
appropriateness of
new products and
services.
18
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
To verify identity
and address and
retrieve contact
phone numbers
and addresses,
establish risk
associated with
address, identity;
Accumio Finance Services GmbH (Germany),
CEG Creditreform Boniversum GmbH
(Germany), Bürgel Wirtschaftsinformationen
GmbH & Co. KG (Germany)
research and
Name, address, date
testing as to
of birth, email address,
appropriateness of
account status,
new products and
account balance, and
services.
in case the transfer of
To assist in making
such information is
decisions
legally justified, also
concerning the
certain information on
credit worthiness of negative account
consumers (if they
performance of a
have a German
customer with a
PayPal account
German PayPal
and have
account, for which
specifically
PayPal has requested
consented to such
a creditworthiness
check) and
check from the
merchants,
respective database.
including without
limitation, in
relation to credit
products offered by
PayPal and
offering direct debit
payments as
payment method.
19
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
The
creditworthiness
scores that we
request from these
agencies that
include scores that
are calculated
according to
mathematicalstatistical
procedures.
Please note the
fact that PayPal
requested such
information, and
any negative
account
performance data
disclosed to these
databases in
relation to
customers who
have a German
PayPal account
may potentially be:
• retained by the
database for audit
purposes and for
scoring of such
customer’s
creditworthiness;
20
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
• any such score
may be disclosed
to other third
parties for the
purpose of gauging
creditworthiness.
and
• transferred
outside of the EU
and on a global
basis.
To verify a
customer's identity
and address, carry
Name, address, email
out checks for the
address, date of birth,
prevention and
gender, bank account
detection of failing
details, information on
direct debit
failed direct debit
payments, and of
payments from a bank
crime including
account (without
fraud and/or
linkage to the identity
SCHUFA Holding AG (Germany), infoscore
money laundering,
of the customer), and
Consumer Data GmbH (Germany)
including checks
in case the transfer of
on the linkage of
such information is
the customer and
legally justified, also
its bank account, to certain information on
help determine
negative account
creditworthiness of
performance of a
consumers (if they
customer with a
have a German
German PayPal
PayPal account
account.
and have
specifically
21
© 2015 PayPal. All rights reserved.
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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
consented to such
check) and of
merchants, and for
research and
testing as to
appropriateness of
products and
services.
The
creditworthiness
scores that we
request from these
agencies include
scores that are
calculated
according to
mathematicalstatistical
procedures.
Please note the
fact that PayPal
requested such
information, and
any negative
account
performance data
disclosed to these
databases in
relation to
customers who
have a German
PayPal account
may potentially be:
22
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
• retained by the
database for audit
purposes and for
scoring of such
customer’s
creditworthiness;
• any such score
may be disclosed
to other third
parties for the
purpose of gauging
creditworthiness
and
• transferred
outside of the EU
and on a global
basis.
Further, in relation
to customers who
have a German
PayPal account,
the information on
a failed direct debit
payment may be:
• retained by the
infoscore database
for audit purposes;
and
• (without linkage
to the customer’s
identity) disclosed
to other third
23
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
parties for the
purpose of
preventing failed
direct debit
payments.
Creditreform Berlin Wolfram KG (Germany),
To determine
Verband der Vereine Creditreform e.V.
creditworthiness of
(Germany)
merchants.
World-Check (UK)
To verify identity.
Name, address, emailaddress.
All account
information.
To verify identity,
carry out checks
for the prevention
and detection of
crime including
Global Data Corporation (USA)
fraud, research
Name, address, date
of birth, telephone
number, email address
and testing as to
appropriateness of
new products and
services.
RSA Security Inc. (USA) and RSA Security
Ireland Limited (Ireland)
ID Checker.nl BV (Netherlands) (Ireland)
To verify identity.
All account
information.
To verify identity;
Name, address, email
automatic data
address, date of birth,
extraction from
legal form, company
images of
registration number,
documents, and
VAT number, proof of
document
identity, address,
validation / forgery
ownership of a funding
detection.
instrument or other
Research and
documents requested
testing as to
by PayPal and the
24
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Aristotle International, Inc. (USA)
Purpose
Data Disclosed
appropriateness of
data contained therein
new products and
for Risk / Compliance/
services.
Credit purposes.
To verify identity.
Acxiom Ltd (UK), Acxiom Deutschland GmbH
(Germany) and Acxiom France SAS (France)
Name, address, date
of birth
Name, address, phone
To verify identity.
number, email address
and date of birth.
To assist with
Creditinfo Decision (Czech Republic) and
PayPal’s
All merchant account
DecisionMetrics Limited (UK)
assessment of
information.
merchant risk.
To retrieve risk
information
regarding the IP
and device from
which customers
ThreatMetrix Inc. (USA)
are accessing
PayPal, research
and testing as to
appropriateness of
new products and
IP and hardware
information about
the device (device
ID, User IP address
and cookies). Email
address and other
information
collected during
sign up.
services.
To validate phone
numbers, research
and testing as to
TeleSign Corporation (USA)
Telephone number
appropriateness of
new products and
services.
To re-structure
AddressDoctor GmbH (Germany),
address data into
normalized format.
Name, address, email
address
25
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
To validate and reDeutsche Post Direkt GmbH (Germany), AZ
Direct GmbH (Germany), Deutsche Post Adress
GmbH & Co. KG (Germany)
structure address
data into
Name, address, email
normalized format
address
and to verify name
and address.
To validate images
of identity
documents and
research and
Mitek Systems Inc. (USA)
testing as to
appropriateness of
Proof of identity,
details of bank
accounts and
credit/debit card
information
new products and
services.
Jumio Inc (USA)
To capture and
All data recorded on
validate proofs of
the customer’s identity
identity and
and address
address
documents
To verify identity;
automatic data
extraction from
images of
documents,and
document
Au10tix Limited (Cyprus), AuthenticID LLC
validation / forgery
detection.
Research and
testing as to
appropriateness of
new products and
services.
Name, address, email
address, date of birth,
legal form, company
registration number,
VAT number,
documents proving
identity and address,
ownership of a funding
instrument, or other
documents requested
by PayPal and the
data contained therein
for Risk / Compliance/
Credit purposes.
26
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
Identity validation
and Know Your
Telovia SA (Luxembourg)
Customer (KYC)
Name, address, date
controls conducted
of birth, proof of ID
for anti money
and address
laundering
purposes
Validate and apply
data quality checks
Syniverse Technologies, LLC (USA)
to phone numbers
Name, address, phone
(SMS message to
number.
be sent to the
customer)
Signicat AS (Norway)
To verify and
Name, address, date
authenticate
of birth and e-id
identity
reference number
Research and
testing as to
appropriateness of
new products and
services in relation
to the validation of
BankersAccuity Inc. (USA)
the account data
provided to us by
Customer’s bank
account number and
sort code and / or
IBAN
the user and
conversion of
national account
data information
into IBAN
To verify email
ArkOwl LLC (USA)
address
Fraudscreen Ltd (UK)
To evaluate level
Email address
Name and address
27
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
of fraud risk
LexisNexis, LexisNexis Risk Solutions UK
To assist with
customer
Limited (UK)
authentication
Name, address and
date of birth
To establish
identity through
customer’s social
Trustev Ltd (Ireland)
media data,
Name, address, date
of birth, email address
and account number
connections and
credentials
To identify
customers and
assist with fraud
detection,
prevention, and or
remediation of
fraud, or other
Tracesmart Ltd (UK)
illegal actions or to
Title, name, address,
date of birth and
telephone number
detect, prevent or
remediate
violations of
policies or the
applicable user
agreements.
Zoot Enterprises, Inc. (USA), Zoot Deutschland
GmbH (Germany), Zoot Enterprises Limited
(UK)
To process
All account information
technical
and documents
applications and to
supplied by
provide a data and
customers, to include
document gateway
information used to
for account review,
provide identity and
testing and vetting
address, ownership of
purposes, and to
a funding instrument,
28
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
exchange user
or other documents
information and
requested by PayPal
images of
and the data
documents proving
contained therein for
identity, address
Risk / Compliance /
and ownership of
Credit purposes. This
funding instrument
information may also
with contracted
include IP addresses.
fraud and credit
reference
agencies. To also
aggregate data
from internal and
external data
sources and
provide statistical
analysis in order to
assess the risk of
fraud.
To process
merchant-initiated
and customerauthorized
transactions and to
provide
account/card
First Data Corporation (USA)
processing
services, to store
transaction,
All account information
and documents
supplied by
customers, to include
information used to
provide identity and
address.
payment and other
customer data
related to those
transactions.
29
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
Research and
testing as to
appropriateness of
new products and
La Banque de France (France), GB Group plc
(UK), SysperTec Communication (France)
services used to
Name, address, date
establish risk
of birth, phone
associated with
number, email address
address, identity,
and associated
with a customer’s
credit worthiness.
To detect fraud.
Please note that
data disclosed to
this service
provider may be:
• retained by it for
audit and fraud
prevention
purposes;
• used by it for the
MaxMind, Inc. (USA)
purpose of
All account information
and IP address, credit
card information.
optimising its fraud
detection services
provided to PayPal
and other third
parties; and
• transferred
outside of the EU
and on a global
basis.
Future Route Ltd (UK)
To carry out
Name, address, email
accounting data
address and date of
30
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
analysis of our
birth.
commercial users
for real time creditrisk evaluation.
To facilitate fraud
checking for
Kount, Inc. (US)
payment
processing
globally.
To detect fraud
and mitigate risk
Artefacts Solutions LLC (US)
related to
transaction
processing.
Experian Information Solutions, Inc. (US)
To verify identity,
assist in making
decisions
concerning a
customer’s credit
worthiness, carry
out checks for the
prevention and
detection of crime
including fraud
and/or money
laundering.
Name, address,
device fingerprint data,
details of payment
instruments, and
details of payment
transactions.
Truncated card
number, amount of
transaction,
chargeback ratio,
credit ratio, and
decline ratio.
Name, address, social
security number, date
of birth, business
name, legal name of
business, tax ID,
business phone
number.
Please note that
data disclosed to
these agencies
may be retained by
the applicable
credit reference
and fraud agency
31
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
for audit and fraud
prevention
purposes.
To verify identity,
carry out checks for
the prevention and
detection of crime
including fraud
and/or money
laundering.
Please note that
data disclosed to
Trulioo Information Services, Inc. (US)
these agencies
may be retained by
Name, date of birth,
address, ID number (if
provided).
the applicable
credit reference
and fraud agency
for audit and fraud
prevention
purposes.
To verify identity,
Soda Software Labs Limited
verify linkage
(UK), Aire Labs Limited (UK), Biz Equity LLC
(USA), Bizequity Limited (UK), DueDil Limited
(UK), Creditsafe (UK), Creditsafe USA Inc.
(USA), MiiCard Limited (UK),Yodlee Inc. (USA)
between a
customer and its
bank account or
credit/debit card,
make decisions
concerning a
customer’s credit
worthiness
(including without
limitation, in
relation to credit
products offered
by PayPal), carry
Name, address, phone
number, email
address, date of birth,
length of time at
address, proof of
identity, legal form,
length of time in
business, company
registration number,
VAT number, funding
instrument including
bank account and
credit /debit card
details (if
32
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
out risk
assessment on the
customer and
checks for the
prevention and
detection of crime
including fraud
and/or money
laundering, assist
in debt recovery,
manage PayPal
accounts and
undertake
statistical analysis,
undertake
research and
testing as to
appropriateness of
new products and
services and
system checking.
National Credit Bureau (Russia)
Data Disclosed
appropriate)and
relevant transaction
information (if
appropriate). All
information supplied
when applying for a
product or account
functionality (including
information obtained
from social media
accounts or online
reputation data.)
To receive
Company registration
business
number, name, and
information for
address of business,
risk
name, address, date
assessment, and
of birth of directors,
compliance with
any 'trading as' names,
anti-money
list of companies that
laundering
directors are involved
requirements,
in, date company
such
established/registered.
as establishing
the
corporate
structure
and beneficial
ownership. To
assist in making
33
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
decisions
concerning a
customer’s credit
worthiness
(including without
limitation, in
relation to credit
products offered
by
PayPal), carry out
checks for the
prevention and
detection of crime
including fraud
and/or money
laundering, assist
in debt recovery,
manage PayPal
accounts and
undertake
statistical
analysis,
undertake
research
and testing as to
appropriateness
of
new products and
services and
system checking.
Intuit Inc. (USA), Intuit Limited (UK), The Sage
Group plc (UK), Xero (UK) Limited, Xero Inc.
(USA)
To receive
information for risk
assessment and
assist in making
Name, address, phone
number, email
address, date of birth,
34
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
decisions
concerning a
customer’s credit
worthiness
(including without
limitation, in
relation to credit
products offered
by PayPal), carry
out checks for the
prevention and
detection of crime
including fraud
and/or money
laundering, assist
in debt recovery,
manage PayPal
accounts and
undertake
statistical analysis,
undertake
research and
testing as to
appropriateness of
new products and
services and
system checking.
Yodlee Inc. (USA), Intuit Inc. (USA), Intuit
Limited (UK), The Sage Group plc (UK), Xero
(UK) Limited, Xero Inc. (USA)
To receive
information for risk
assessment and
assist in making
decisions
concerning a
customer’s credit
worthiness
(including without
limitation, in
relation to credit
products offered
by PayPal), carry
out checks for the
prevention and
detection of crime
including fraud
Data Disclosed
length of time at
address, proof of
identity, legal form,
length of time in
business, company
registration number,
VAT number, funding
instrument including
bank account and
credit /debit card
details (if appropriate)
and relevant
transaction information
(if appropriate).
Name, address, phone
number, email
address, date of birth,
length of time at
address, proof of
identity, legal form,
length of time in
business, company
registration number,
VAT number, funding
instrument including
bank account and
credit /debit card
35
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
and/or money
laundering, assist
in debt recovery,
manage PayPal
accounts and
undertake
statistical analysis,
undertake
research and
testing as to
appropriateness of
new products and
services and
system checking.
Data Disclosed
details (if appropriate)
and relevant
transaction information
(if appropriate).
5. Financial Products
To resolve
technical issues
La Poste (France)
and user claims
Any Account
(when PayPal is
information necessary
being offered by
to resolve the issue or
the merchant
claim
through La Poste’s
payment solution).
To conduct joint
marketing
campaigns for
PayPal Credit, and
PayPal
MasterCard, risk
Santander UK Cards Limited (UK)
modelling, enforce
terms and
Name, address, email
address and account
information (including,
without limitation,
account status).
conditions for
PayPal Credit and
PayPal
MasterCard.
36
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
To conduct joint
marketing
campaigns for
TSYS Card Tech Limited (UK), TSYS Managed
Services EMEA Limited (UK), PrePay
Technologies Limited (trading as PrePay
Solutions) (UK)
PayPal pre-paid
card and risk and
fraud modelling
and to enforce
Name, address, email
address, date of birth
and account
information.
terms and
conditions for
PayPal prepaid
card.
Only for merchants
using PayPal through
the partner’s payment
solution: merchant ID,
Société Générale (France), La Banque Postale
(France), BNP Paribas (France) and Crédit
number of PayPal
Billing purposes.
Mutuel (France)
transactions,
transaction volume
with PayPal and, as
the case may be,
termination of the
PayPal account.
Registration of the
credit card issued
by the credit
company on the
Findomestic Banca (Italy), Cetelem S.A., Cofidis
user’s PayPal
(France) and Cofinoga S.A. (France)
account and the
processing of
funding requests
made by the same
user.
Name, email address,
date of birth (as the
case may be), credit
card number, expiry
date, three digit Card
Security Code (as the
case may be) and
amount of the funding
request and any
account information
necessary for fraud or
37
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
dispute resolution.
To process
merchant initiated
and customer
authorised
payments
(including
Total System Services, Inc. (USA)
customer direct
Name, address, email
debit information)
address, date of birth
to provide
(where required), all
account/card
account information
processing
and documents
services, to store
supplied by
transaction,
customers, to include
payment and other
information required to
customer data
prove identity and
related to those
address.
transactions. To
provide call centre
services, card
printing, and
statement printing
services.
Only for PayPal
To enable you (or
the merchant with
United Kapital Limited (UK) and United Kapital
Limited, LLC (USA)
which you transact)
to use products
issued by United
Kapital with
PayPal.
merchants applying for
and using products
issued by United
Kapital Limited: Name,
business name,
address, date of birth,
copies of identification
documents, PayPal
identification
38
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
(merchant ID), email
address, phone
number, transaction
information (including,
without limitation,
number of PayPal
transactions and
transaction volume
with PayPal), length of
time as a PayPal user
and, as the case may
be, termination of the
PayPal account.
For customers of
those merchants:
transaction
information, name,
email address, phone
number, address and
PayPal identification
number.
6. Commercial Partnerships
To provide
automated label
printing for sellers
using PayPal and
Royal Mail Group Plc. (UK) and Pitney Bowes
eBay to facilitate
Inc. (USA)
postal and delivery
Name, address, email
address and postage
transaction amount.
services, including
payment
reconciliation
services.
39
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
To provide
customised
services and
assistance to
Merchants using
Trustwave (USA)
PayPal, and to
Name, email address
and PayPal account
number.
facilitate the
process of
becoming PCI DSS
compliant.
First and last name,
Stubhub Services S.à.r.l. (Luxembourg)
For the purposes
date of birth,
of its AML and
residential address,
KYC requirements.
nationality, national
ID/passport number
Harrow Council (UK)
Pay out funds to
All Account
benefit recipients
Information.
using PayPal.
VODAFONE SALES & SERVICES LIMITED
Marketing and
(UK)
management to
allow PayPal to
operate with third
party products like
the Vodafone
Wallet
First, Last Name,
Billing Address (Street
Name, House Number,
City, State, Postal
Code, Country), Payer
ID, Given Payment
Method, CMID / Client
Metadata ID, e-mail.
Cloud IQ (United Kingdom)
Providing
assistance with
PayPal services to
business
customers.
Customer name,
business name, phone
numbers, contact
email addresses,
website,
business industry,
40
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
number of PayPal
transactions,
transaction volume
with PayPal, domestic
/ international
transaction volume
split,
shipping details, card
details for the
payment.
WebInterpret (France)
Providing
assistance with
PayPal services to
business
customers.
Customer name,
business name, phone
numbers, contact
email addresses,
website,
business industry,
number of PayPal
transactions,
transaction volume
with PayPal, domestic
/ international
transaction volume
split,
shipping details, card
details for the
payment.
7. Marketing and Public Relations
Name, email address,
Decipher Inc. (USA), Northstar Research
Partners (USA)
To conduct
customer service
surveys.
type of account, type
and nature of the
PayPal services
offered or used, and
relevant transaction
41
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
information.
Name, email address,
phone number, type of
Ipsos Mori UK Limited (UK), Ipsos GmbH
To conduct
account, type and
(Germany), Ipsos SAS (France) and FactWorks
customer service
nature of the PayPal
GmbH (Germany), TNS Deutschland GmbH
and marketing
services offered or
(Germany)
surveys.
used, and relevant
transaction
information.
Name, email address,
phone number, type of
account, type and
Adwise (France) and Axance (France)
To conduct
nature of the PayPal
marketing surveys.
services offered or
used, and relevant
transaction
information.
BD Network Limited (UK), Tullo Marshall Warren
To develop and
execute customer
Limited (UK), and MyCash (France)
promotions.
Name, address and
email address.
Name, address, phone
number and email
To store merchant
contact information
as well as other
Salesforce.com, inc. (USA)
supporting
information about
the business
relationship.
address, business
name, URL PayPal
Account ID and other
supporting information
about the business
relationship, such as
(without limitation)
name of contact
person and contact
information at
42
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
merchant and/or
partner through which
merchant has been
onboarded, description
of products sold
through PayPal,
communication notes
and onboarding
information, internal
decisions about the
merchant, revenue
calculations and other
information on the
merchant’s business
as made available by
the merchant, and
information relevant
for special integrations
of merchants, name
and address of bank.
Daniel J Edelman Ltd (UK), I&E Consultants
(France), Grayling Communications Limited
(UK), Rock Communications (Italy), Fleisher
(Israel), Clue PR (Poland).
To answer media
enquiries regarding
customer queries.
To allow
management
Alchemy Worx Ltd (UK)
reporting of
marketing
campaigns.
Carrenza Limited (UK)
Name, address, and
all customer account
information relevant to
customer queries.
Name, email address
and details of
customer campaign
interaction.
To store user data
Name, address, email
for marketing
address, business
campaigns.
name, domain name,
43
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
account status,
account preferences,
type and nature of the
PayPal services
offered or used, and
relevant transaction
information.
Name, email address,
To store user data
1000Mercis SA (France) and 1000Mercis Ltd
to conduct
marketing
(UK)
campaigns on
behalf of PayPal.
phone number, type of
account, type and
nature of the PayPal
services offered or
used, and relevant
transaction
information.
Name, address, email
address, business
To assist in the
A McLay & Company Limited (UK), TNT Post
execution of offline
direct mail and
Italia (Italy)
marketing
campaigns.
name, domain name,
account status,
account preferences,
type and nature of the
PayPal services
offered or used, and
relevant transaction
information.
Name, email address,
To assist in the
address, business
Datacolor Dialog-Medien GmbH (Germany),
execution of offline
name, domain name,
MEILLERGHP GmbH (Germany) and W & J
direct mail and
account status,
Linney Ltd (UK)
marketing
account preferences,
campaigns.
type and nature of
PayPal services
44
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
offered or used.
Name, email address,
type of account, type
Medallia, Inc. (USA)
To conduct
and nature of the
customer service
PayPal services
surveys.
offered or used, and
relevant transaction
information.
To assist in the
Name, address,
Endlichsommer- werbung in bester gesellschaft
execution of offline
business name, type
mbh (Germany) and Crossover Communication
direct mail and
and nature of PayPal
GmbH (Germany)
marketing
services offered or
campaigns
used.
Name of the merchant,
To send emails;
optivo GmbH (Germany)
email marketing
name of the contact
person, email address,
address, status, client
ID and shop system
To collect
additional user
Acxiom France SAS (France), Acxiom Ltd (UK)
information and
and Acxiom GmbH (Germany)
better target
Name, address, email
address, date of birth
and phone number.
marketing
campaigns.
Name, business
name, address and
Rapp (France), Antics (US), Partner Path
To develop,
registration number of
measure and
merchant/partner,
execute marketing
name, job, title, email
campaigns.
address, phone
number of merchant’s
contact person,
45
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
merchant website
URL, PayPAl account
number, third party
applications used by
the merchant,
behaviour on PayPal
Serviceswebsite.
Name, email address,
phone number, type of
To execute e-mail
DemandGen AG (Germany)
marketing
campaigns
account, type, and
nature of PayPal
Services offered or
used and relevant
transaction
information.
To store
Name of the merchant,
merchants' contact
name of the contact
Business support services - b2s, SAS (France),
information for
person, address, email
Foule Access SAS (France)
marketing
address, phone
communications to
number, merchant
those merchants.
website URL.
To host information
All information
provided by
provided by merchants
merchants and
in connection with their
display part of this
use of these pages of
information on the
the PayPal website
pages of the
(including in particular
PayPal website
name of the merchant,
listing websites
name of the contact,
accepting PayPal
email address, logo
and proposing
and information
special offers to
relating to the
Consultix (France and Spain) and Quadro Srl
(Italy)
46
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
PayPal users.
promotion(s) offered to
PayPal users).
Anonymous ID
Appnexus, Inc. (US), BlueKai, Inc. (US), Adobe
Systems Incorporated (US), Mediamath Inc.
(US), Criteo SA (France), TubeMogul Inc (US),
AdaptTV
To execute
generated by cookies,
retargeting
pixel tags or similar
campaigns in order
technologies
to deliver
embedded in
personalised
webpages, ads and
advertising.
emails delivered to
users.
Google Inc., Google Ireland, Ltd. (Ireland),
DoubleClick Europe Ltd (UK), DoubleClick, a
division of Google, Inc
Help identify
Anonymous ID
behaviour on
generated by cookies,
PayPal websites
pixel tags or similar
and the mobile app
technologies
in order to guide
embedded in
decision about
webpages, ads and
targeted marketing; emails delivered to
to help efficiently
users. Advertising ID
handling and
and device ID to
optimising desktop
segment user groups
and mobile
based on app
campaigns and
behaviour, encrypted
elsewhere in the
e-mail address
web and execute
associated with
retargeting
PayPal users (without
campaigns in order
indicating account
to deliver
relationship).
personalised
Conversant Inc. (USA), Commission Junction
(USA), Conversant GmbH (Germany),
Conversant International Ltd. (Ireland)
advertising.
To execute and
measure
retargeting
Hashed PayPal
Account ID (as
appropriate) as well as
campaigns in order
47
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
to identify visitors
and redirect them
though
personalised
advertising
campaigns.
Data Disclosed
,device ID used by a
specific person,
content of
advertisements to be
delivered, and
segmentation in a user
group for
advertisement
purposes.
To execute
retargeting
campaigns in order
Criteo SA (France)
to deliver
personalised
advertising.
To execute
retargeting
campaigns in order
Linkedin Ireland Limited (Ireland)
to deliver
personalised
advertising.
Conversant Inc. (USA)
Anonymous ID
generated by cookies,
pixel tags or similar
technologies
embedded in
webpages and emails
delivered to users.
Encrypted e-mail
address associated
with PayPal users
(without indicating
account relationship).
To execute and
PayPal Account ID (as
measure
appropriate) as well as
retargeting
device ID used by a
campaigns in order
specific person,
to identify visitors
content of
and redirect them
advertisements to be
though
delivered and
personalised
segmentation in a user
advertising
group for
campaigns.
advertisement
48
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
purposes.
StrikeAd UK Ltd. (UK), Criteo Ltd. (UK), Criteo
Singapore Pte. Ltd (SP), Tapjoy Inc (US).,
To execute and
Supersonic Ltd., StrikeAd Inc. (US), Exponential
measure
Interactive Inc (US), InMobi (US), MoPub Inc.
retargeting
(US), AdMob Inc (US), Millenial Media Inc (US),
campaigns in order
Tapad Inc, Drawbridge Inc, Mobkoi, (UK) Fiksu,
to segment users
Inc. (US), Nanigans, Inc. (US), Eloqua, a
for PayPal Here
division of Oracle Inc.,Criteo SA (France),
marketing
Rocket Fuel, StrikeAd Inc. (US)
campaigns.
Anonymous cookie ID,
Advertising ID, and/or
device ID to segment
user groups for
marketing purposes.
To execute and
Fiksu, Inc. (US)
measure
Device ID used for
retargeting
Apple’s iOS operating
campaigns in order
system when a user
to segment users
installs an application,
for marketing
signs up for the
campaigns
PayPal Services, logs
involving PayPal
in, checks in, or sets a
mobile
profile picture.
applications.
Advertising ID
associated with Apple
iOS devices when a
To execute
retargeting
campaigns in order
Nanigans, Inc. (US
to deliver
personalised
advertising.
user installs an
application,
relaunches an
application, signs up
for the PayPal
Services, logs in,
checks in, checks their
balance, saves an
offer, successfully
completes a
49
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
transaction, sets a
profile picture, or
makes other account
changes in or related
to the use of the
application.
To execute
marketing
Heaven SAS (France)
campaigns for
merchants.
To notify winners
and prize fulfillment
Tenthwave Digital, LLC (USA)
for winners of
survey
sweepstakes
Name of merchant,
merchant website
URL, description of
item purchased and
price of item.
Name and email
address, for
sweepstakes winners
and alternates only.
To store user data
for marketing
Sotiaf Telematiques Associes SAS (France)
campaigns and to
Name, email address,
execute direct
and phone number.
marketing
campaigns.
Name, company
name, address,
telephone number,
domain name, e-mail
2engage (Germany) and Quo Vadis (Germany)
To conduct market
address, type and
surveys.
nature of use of
PayPal services,
market segment and
generalised
categorisation of
50
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
company size and
information on
participation in earlier
surveys.
Advertising ID and
device ID to segment
user groups based on
app behaviour,
encrypted e-mail
To execute
retargeting
Facebook, Inc (USA), Facebook Ireland Limited
campaigns in
(Ireland), Twitter, Inc. (USA), AdRoll, Yahoo
order to deliver
personalised
advertising.
address associated
with PayPal users
(without indicating
account relationship).
Anonymous ID
generated by cookies,
pixel tags or similar
technologies
embedded in
webpages, ads and
emails delivered to
users.
SurveyMonkey Spain, Sucursal em Portugal
(Portugal) and SurveyMonkey.com, LLC (USA)
Marketing and Planning Systems, LLC. USA
(USA), Dynamic Logic, Inc. (USA), GfK Custom
Research LLC (USA), Millward Brown, Inc.
(USA) and Radius Global Market Research, LLC
(USA)
To assist in
carrying out user
surveys.
Name, email address
and details of
customer campaign
interaction.
Name, email address,
To conduct
type of account, type
customer service
and nature of PayPal
and marketing
services offered or
surveys
used, and relevant
transaction information
Oracle America Inc. (USA),
To develop,
Name, business
51
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
Oracle Corporation UK Ltd
measure and
name, address and
execute marketing
registration number of
campaigns.
merchant, name, job
title, email address,
phone number of
merchant’s contact
person, merchant
website URL, PayPal
account number, third
party applications
used by the merchant,
behaviour on PayPal
website.
Anonymous cookie ID,
Advertising ID, and
Device ID used by a
specific person, events
Nanigans, Inc. (USA), Fiksu, Inc. (USA), Ad- X
Limited (UK); Criteo Ltd. (UK), Criteo Singapore
Pte. Ltd
Help identify
in the mobile app
behaviour in the
about the use of the
mobile app in order
mobile app by a
to guide decision
specific user
about targeted
(including, without
marketing; to help
limitation, login,
efficiently handling
successful completion
and optimising
of the transaction), but
mobile campaigns
no payment and
on social networks
financial information
and elsewhere in
details.
the web
Content of
advertisements to be
delivered to specific
users and, as
appropriate,
52
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
segmentation group to
which such person
belongs to for
advertisement
purposes.
To store
Name of the merchant,
merchants' contact
name of the contact
Zeuner S.p.A. (Italy), Accueil Srl (Italy) and
information for
person, address, email
CallCenterNet Italy s.r.l. (Italy)
marketing
address, phone
communications to
number, merchant
those merchants.
website URL.
Mobile Number, name,
address, email
address, business
To send service
related and
(depending on optPurepromoter Ltd t/a Pure360
in settings)
promotional SMS
messages to
PayPal users.
name, business
contact details,
domain name, account
status, account type,
account preferences,
type and nature of the
PayPal services
offered or used and
relevant transaction
and account
information
Name, business
To develop,
measure and
Iris (Germany)
execute marketing
campaigns.
name, address and
registration number of
merchant/partner,
name, job title, email
address, phone
number of merchant’s
53
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
contact person,
merchant website
URL, PayPal account
number, third party
applications used by
the merchant,
behaviour on PayPal
website.
OC&C Strategy Consultants Limited (UK)
To conduct market
research and
develop insight
Anonymized account
and transaction
information
Managing
marketing
campaigns,
distributing flyers to
merchants and
follow up of the
campaigns.
PaketPLUS Marketing GmbH (DE)
To conduct
customer service
and marketing
surveys.
Eye square GmbH (DE)
Alliance Data FHC, Inc., trading as Epsilon
International and/or Epsilon Communication
Solutions, S.L
To execute
outbound
communication
campaigns
including, but not
limited to, email
and push
notifications.
Consumer name,
Location, Nature and
scale of fraud on the
account, Business
name.
To conduct
customer service
and marketing
surveys.
Contact information
inluding, but not
limited to, name,
email, telephone
number. Anonymous
cookie ID, Advertising
ID. Content of
communications to be
delivered to specific
users and, as
appropriate,
segmentation group to
54
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
which such person
belongs to for
communication
Help identify
behaviour in the
mobile app in order
to guide decision
about targeted
marketing; to help
efficiently handling
and optimising
mobile campaigns
on social networks
and elsewhere in
the web.
Adjust GmbH (Germany)
purposes.
Anonymous cookie ID,
Advertising ID, and
Device ID used by a
specific person, events
in the mobile app
about the use of the
mobile app by a
specific user
(including, without
limitation, login,
successful completion
of the transaction), but
no payment and
financial information
details.
Content of
advertisements to be
delivered to specific
users and, as
appropriate,
segmentation group to
which such person
belongs to for
advertisement
purposes.
Cross Device /
Channel
Measurement.
Visual IQ, Inc (US)
Advertising ID and
device ID to segment
user groups based on
app behaviour,
55
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
encrypted e-mail
address associated
with PayPal users
(without indicating
account relationship).
Anonymous ID
generated by cookies,
pixel tags or similar
technologies
embedded in
webpages,ads and
emails delivered to
users.
8. Operational services
Name, address, phone
number, account
number, date of birth,
email address,
Kanzlei Dr. Seegers, Dr. Frankenheim & Partner
account type, account
Lawyers (Germany, Austria, Switzerland),
status, last four digits
Akinika Debt Recovery Limited (UK), Capita Plc
of financial
(UK), Compagnie Francaise du Recouvrement
instruments account,
(France), Clarity Credit Management Solutions
Limited (UK),; EOS Solution Deutschland GmbH
(Germany), EOS Aremas Belgium SA/NV
(Belgium), EOS Nederland B.V. (Netherlands),
Arvato Infoscore GmbH (Germany), Infoscore
Iberia (Spain), , SAS (France), Transcom
WorldWide S.p.A. (Italy), Transcom Worldwide
SAS (Tunisia), Intrum Justitia S.p.A. (Italy),
sort code, account
To collect debt.
balance, details of
account transactions
and liabilities, name of
funding source
provider and copies of
all correspondence in
each case relating to
amounts you owe (or
another person owes)
to us.
56
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
Name, address, phone
number, account
number, date of birth,
email address,
account type, account
status, last four digits
of financial
instruments account,
sort code, account
KSP Kanzlei Dr. Seegers (Germany), BFS Risk
balance, details of
& Collection GmbH (Germany); HFG
Hanseatische Inkasso- und Factoring-
To collect debt; to
Gesellschaft (Germany),BFS Risk and Collection handle reporting to
GmbH (Germany), Team 4 Collect (Spain),
credit reference
Arvato Polska (Poland), BCW Collections Ireland
agencies about
Ltd (Ireland), S.C. Fire Credit S.R.L. (Romania),
defaulting
Gothia Financial Group AB (Sweden), Gothia AS
customers.
account transactions
and liabilities, name of
funding source
provider, applicable
details of account
behaviour and copies
of all correspondence
(Norway), Gothia A/S (Denmark), Gothia Oy
(including without
(Finland), Credit Solutions Ltd (United Kingdom).
limitation, all
correspondence
relevant for reporting
to credit reference
agencies) in each
case relating to
amounts you owe (or
another person owes)
to us.
Begbies Traynor Group plc (UK), Moore
To investigate
Name, address, phone
Stephens LLP (UK), Moore Stephens Ltd (UK),
(including, without
number, account
Moore Stephens International Ltd (UK),
limitation, to carry
number, date of birth,
Moorhead James LLP (UK), Comas Srl (Italy),
out asset and/or
email address,
RBS RoeverBroennerSusat GmbH & Co. KG
site inspections
account type, account
(Germany), LLC Elitaudit (Russia), National
and/or business
status, last four digits
57
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
Recovery Service (Russia).
evaluations) and/or
of financial
collect (and/or
instruments account,
assist with the
sort code, account
collection of) debt
balance, details of
from potentially
account transactions
and actually
and liabilities, name of
insolvent
funding source
customers
provider and copies of
all correspondence, in
each case relating to
amounts you owe (or
another person owes)
to us.
Name, address, phone
number, account
number, date of birth,
Only for customers
who are also
customers of Bill
Webbank (USA)
Me Later, Inc.: to
help with
accounting and
recovery services
email address,
account type, account
status, last four digits
of financial
instruments account,
sort code, account
balance, details of
account transactions
and liabilities, and
name of funding
source provider.
To enable you to
Applicable details of
access and use
your account
Digital River Inc. (USA) and Research in Motion
PayPal via a
information which are
Limited (USA)
mobile device (for
transmitted as part of
example mobile
your use of PayPal via
phone or PDA).
a mobile device.
58
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
Name, address, phone
number, account
number, date of birth,
business name, email
mediafinanz AG (Germany)
To collect debt, to
address, account type,
request and
account status, last
proceed
four digits of financial
information from
instruments account,
and to Schufa,
account balance,
Buergel and other
details of account
credit reference
transactions and
and fraud agencies
liabilities, name of
for PayPal
funding source
provider, credit score
received from agency,
account performance
data
Name, address, phone
number, account
number, email
address, account type,
To collect and
Zyklop Inkasso Deutschland GmbH (Germany),
PNO inkasso AG (Germany), Hanseatische
Inkasso-Treuhand GmbH (Germany)
manage debt, to
support collections
teams in case of
insolvent
customers
account status, last
four digits of financial
instruments account,
sort code and name of
funding source
provider, account
balance, date and
amount of last
payment, results of
creditworthiness
checks
Informa Solutions GmbH (Germany)
To request and
Name, date of birth
59
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
proceed
business name, legal
information from
form, address, email
and to Schufa,
address, company
Buergel and other
registration number
credit reference
and VAT number.
and fraud agencies
For the purpose of
in and from and to
verification of identity
ID Checker
also: other information
contained in
documents requested
by PayPal for Risk /
Compliance purposes.
For customers with a
German PayPal
account also: phone
number, length of time
at address, length of
time in business,
length of time with
PayPal, funding
instrument including
bank account and
credit /debit card
details and relevant
transaction
information, credit
score received on
behalf of PayPal from
a credit reference
agency, account
number, account type,
account status,
account balance,
60
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
details of account
transactions and
liabilities, negative
account performance
data.
Name, address, phone
number, account
number, email
address, account type,
To assess risk and
help detect and
prevent potentially
P K Consultancy Limited (UK)
illegal acts and
violations of
policies.
last four digits of
financial instruments
account, account
balance, details of
account transactions
and liabilities, account
status and account
performance
information as
required for the
Purpose
Name, address, phone
number, account
number, business
Consultation with
respect to risk
Robertson Taylor Insurance Brokers Limited
assessment of
(UK)
specific merchants
and merchant
transactions
contact details,
domain name, email
address, account type,
account balance,
details of account
transactions and
liabilities, account
status and account
performance
information as
61
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
required for the
Purpose.
To fulfil email
operations in
respect of the
Yesmail Inc. (USA), Responsys (USA),
Silverpop Systems Inc. (USA) and e-Dialog, Inc.
(USA), Salesforce.com, Inc. (USA), Oracle
America Inc. (USA), Adobe Systems
Incorporated (USA), Teradata Corporation
PayPal services
(including, but not
limited to,
operations,
customer services,
collections,
marketing
programmes and
promotions).
Name, address, email
address, business
name, business
contact details,
domain name, account
status, account type,
account preferences,
type and nature of the
PayPal services
offered or used and
relevant transaction
and account
information.
To verify identity
and ensure that a
user is a PayPal
account holder. To
Blue Media S.A. (Poland)
process instant
Name and email
address.
funding requests
made by a user
through the Blue
Media services.
Consultix GmbH (Germany)
To assist in the
All information
creation of PayPal
provided by the
Business Accounts
merchant (directly or
for merchants on-
via his/her bank or
boarding through
other contract partner)
their bank's or
for the purpose of
other contract
creating his/her
partner payment or
PayPal business
62
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
service gateway.
account (including
without limitation email
address, address,
business name,
business contact
details and bank
account details).
Content delivery
network – to
deliver PayPal
page content from
local servers to
users. To also
retrieve risk
information
Akamai Technologies Inc. (USA)
regarding the IP
and device from
which customers
are accessing
IP and hardware
information about
the device (device
ID, User IP
address cookies).
Circumstances of
the conduct of IP.
PayPal, research
and testing as to
appropriateness of
new products and
services.
To distribute prizes
azionare GmbH (Germany)
in prize promotions
Name, email address.
on Facebook.
To assist in the
ITELLIUM mobile Solutions GmbH (Germany);
production of
innovative payment
CartaSi S.p.A - Gruppo ICBPI (Italy)
All account
information.
methods (e.g.
applications) and
63
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
processing of
payments through
such innovative
payment methods.
Business name,
To provide PCI
compliance
validation services
Trustwave Holdings Inc. (USA)
for merchant
accounts and
merchant
integrations.
address, account
number, merchant
type, compliance
program used, PCI
Level, PCI Status, PCI
Expiry, name, email
address, phone
number of merchant’s
contact person
To process
technical
applications and to
provide a data and
document gateway
for account review,
testing and vetting
purposes, and to
Zoot Enterprises, Inc. (USA), Zoot Deutschland
exchange user
GmbH (Germany), Zoot Enterprises Limited
information and
(UK)
images of
documents proving
identity, address
and ownership of
funding instrument
All account information
and documents
supplied by customers
such as proofs of
identity and address,
ownership of a funding
instrument, or other
documents requested
by PayPal and the
data contained therein
for Risk / Compliance
Credit purposes.
with contracted
fraud and credit
reference
agencies.
64
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
To provide printing
RR Donnelley and Sons Company (USA)
services such as
Name, address, email
statements and
address, and account
other printed
information
materials
Scorex (UK) Limited (UK)
To provide a
Name, address, email
technology solution
address, date of birth,
to allow PayPal to
length of time at
process, send and
address, phone
receive credit
number, legal form,
information of
length of time in
users via its
business, company
contracted credit
registration number,
reference
VAT number (if
agencies.
appropriate).
Services in
connection with the
development and
OXID eSales AG (Germany)
operation of a
payment system
All account information
and transaction
information (as
appropriate).
for stationary trade
(point of sale)
To collect data and
create/deliver
(direct to customer)
orders for the
Ordermotion, Inc. (USA)
PayPal Here
product (including,
Name, address, email,
phone number, credit
card information and
PayPal Payer ID.
without limitation,
the PayPal Hereenabled device).
Ingram Micro, Inc. (USA) and Ingram Micro (UK)
To act as PayPal's
Name and address.
65
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Limited (UK)
fulfilment
Data Disclosed
distributor for the
PayPal Here
product (including,
without limitation,
the PayPal Hereenabled device).
To provide data
centre operations
Interxion Datacenters B.V.
support for the Bill
Safe credit
product.
All relevant account
information and
transaction information
(as appropriate).
Name of the merchant,
Lattice Engines, Inc.
To develop and
name of the contact
optimize predictive
person, address, email
models.
address, merchant
website URL
Customer name,
Providing
assistance with
Interact CC Ltd (UK)
PayPal service to
customers
business name, phone
numbers, contact
email, website,
business industry,
shipping details, card
details for the payment
The unbelievable Machine Company GmbH
Hosting BillSafe
application on its
servers
eBay Enterprise (GSI Commerce) (US)
All Account
information.
Processing of
Name, address,
PayPal payments
phone
and provision of
number, email
customer support
addresses,
on merchants
truncated
66
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
behalf.
and limited,
funding
source expiration
dates, type of
PayPal
account, account
status, last four
digits
of financial
instruments
account,
sort code, account
balance, details of
account transactions.
Globalcollect (NL)
Process PayPal
Name, address,
transactions,
phone
facilitate settlement
number, email
of funds outside of
addresses,
the PayPal system
truncated
and reporting.
and limited,
funding
source expiration
dates, type of
PayPal
account, account
status, last four
digits
of financial
instruments
account,
sort code, account
67
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
balance, details of
account transactions.
9. Group companies
Acting on behalf of
PayPal for the
PayPal Inc. (USA)
purposes of storing
All Account
and processing of
information.
Account
information.
PayPal Europe Services Limited (Ireland),
PayPal Malaysia Services Sdn Bhd (Kuala
Lumpur), PayPal Israel Ltd (Israel), PayPal India
Private Limited (India), PayPal (UK) Ltd (UK),
PayPal France S.A.S. (France), PayPal
Deutschland GmbH (Germany), PayPal Spain
Acting on behalf of
SL (Spain), PayPal Italia Srl (Italy), PayPal
PayPal for the
Nederland BV (Netherlands), PayPal European
purpose of
Marketing SA (Switzerland), PayPal Polska Sp
customer support,
Zoo (Poland), PayPal Bilisim Hizmetleri Limited
risk assessment,
Sirketi (Turkey), PayPal International Sarl
compliance and/or
(Luxembourg), PayPal SE (UK), Bill Me Later
other back office.
All Account
information.
Inc. (Germany), PayPal Information
Technologies (shanghai) Co., (China), PayPal
Australia Pty Limited (Australia), PayPal
Charitable Giving Fund (USA), PayPal Giving
Fund UK (UK), Tradera AB (Sweden),
Acting for the
account of PayPal
PayPal Pte. Ltd. (Singapore)
by entering into
All Account
and performing
information.
non-customer
contracts which
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© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
involve customer
data.
10. Commercial partners
eBay Inc. (USA), eBay Europe S.à r.l.
(Luxembourg), eBay Services S. à r.l.
(Luxembourg), eBay International AG
(Switzerland), eBay Corporate Services GmbH
To provide joint
(Germany), eBay France SAS (France), eBay
customers content
(UK) Limited (UK), eBay CS Vancouver Inc.
and services
(Canada), eBay Partner Network Inc. (USA),
(including, but not
eBay Internet Support (Shanghai) Co Ltd
limited to
(China), eBay Enterprise Marketing Solutions
registration,
(USA) (formerly GSI Commerce, Inc (USA),
transactions,
VendorNet Inc (USA), PepperJam Network
failover for carrier
(USA), GSI Media Inc. (USA), M3 Mobile Co.,
billing accounts,
Ltd. (Korea), MBS (USA), ClearSaleing (USA),
and customer
True Action Network (USA), True Action Studio
support), to assess
(USA)), GumTree.com Limited (UK), Kijiji
risk, or to help
International Limited (Ireland), Kijiji US Inc.
detect, prevent
(USA), mobile.de & eBay Motors GmbH
and/or remediate
(Germany), Shopping.com Inc. (USA), Shopping
fraud, or other
Epinions International Limited (Ireland),
potentially illegal
Marktplaats B.V. (Netherlands), Private Sale
acts and violations
GmbH (Germany), StubHub, Inc. (USA), Viva
of policies, and to
Group, Inc. (USA), StubHub Europe S.à r.l.
guide decisions
(Luxembourg), StubHub Services S.à r.l.
about their
(Luxembourg), Viva Group, Inc. (USA),
products, services
ProStores Inc. (USA), MicroPlace, Inc. (USA),
and
Internet Auction Co., Ltd. (Korea), Via-Online
communications.
All Account
information.
GmbH (Germany), Zong Inc.(USA) and
X.commerce, Inc. (USA). eBay Europe Services
Limited (Ireland), eBay GmbH (Germany)
69
© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.
List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared
As of: February 23, 2016
Category
Party Name and Jurisdiction (in brackets)
Purpose
Data Disclosed
11. Agencies
CSSF (Luxembourg), CNPD (Luxembourg),
Financial Ombudsman Service (UK),
Altroconsumo (Italy), European Consumer
To provide the
Centre Network organisations (located in
Agencies listed
Austria, Belgium, Bulgaria Czech Republic,
with information
Cyprus, Denmark, Estonia, Finland, France,
within their
Germany, Greece, Hungary, Iceland, Ireland,
authority (upon
Italy, Latvia, Lithuania, Luxembourg, Malta,
their request) and
Netherlands, Norway, Poland, Portugal,
to respond to
Romania, Slovakia, Slovenia, Spain, Sweden,
queries and/or
and the UK), Les Mediateurs du Net (France),
investigations
Risolvi Online (Italy) and BaFin (Germany), Data
instigated by users
Protection Agencies located in Austria, Belgium,
or other
Bulgaria Czech Republic, Cyprus, Denmark,
stakeholders in the
Estonia, Finland, France, Germany, Greece,
countries where
All account information
Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, they have
Luxembourg, Malta, Netherlands, Norway,
jurisdiction.
Poland, Portugal, Romania, Slovakia, Slovenia,
Spain, Sweden, and the UK.
With respect to the column titled, "Purpose", each third party, with the exception of the regulatory
agencies, certain of the payment processors and credit reference and fraud 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. Where explicitly specified in the
table, the payment processors and credit reference and fraud agencies may use the information in
their respective databases, and forward information to third parties for the purposes of fraud
prevention and the assessment of creditworthiness, in accordance with their respective terms.
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© 2015 PayPal. All rights reserved.
PayPal (Europe) S.à r.l. et Cie, S.C.A.