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Privacy policy



Welcome to the​​ Active​​ Merchant​​ Services​​ Limited (“Active”)​​ privacy notice.​​ 

Active​​ respects​​ your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.​​ 

  • Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how​​ Active​​ collects and processes your personal data.​​ 

We do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.​​ 


We have appointed a data protection​​ manager​​ who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the​​ data protection manager​​ using the details set out below.​​ 

Contact details

To contact us about anything to do with your personal data and data protection (including to make a data subject access request) our full details are:

Name or title:​​ Data Protection​​ Manager

Email address:​​

Postal address:​​ Suite 3D MIOC, Styal Road, Manchester, M22 5WB

Telephone number: 0161 499​​ 9747

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.​​ 

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

  • The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you,​​ including:​​ 

  • Identity Data​​ includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

  • Contact Data​​ includes billing address, delivery address, email address and telephone numbers.

  • Financial Data​​ includes bank account and payment card details.

  • Transaction Data​​ includes details about payments to and from you and other details of products and services you have purchased from us.

  • Marketing and Communications Data​​ includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We​​ may​​ also collect, use and share​​ Aggregated Data​​ through our website​​ such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does​​ not​​ directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any​​ Special Categories of Personal Data​​ about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).​​ We​​ also do not​​ collect any information about criminal convictions​​ or​​ offences.

  • How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions.​​ You may give us your Identity, Contact and Financial Data by:​​ 

    • filling in forms or by corresponding with us by post, phone, email or otherwise.​​ 

    • apply for our products or services;

    • create an account on our website;

    • request marketing to be sent to you;

  • Third parties or publicly available sources.​​ We may receive personal data about​​ you from various third parties​​ and public sources​​ including​​ as set out below:

    • Technical Data from analytics providers or search information providers.

    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

    • Identity and Contact Data from data brokers or aggregators.​​ 

    • Identity and Contact Data from publicly availably sources.​​ 

  • How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:​​ 

  • Where we need to perform the​​ contract,​​ we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.​​ 

  • Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please​​ contact us​​ if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.​​ 


Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity​​ 

(b) Contact

Processing which is necessary for the performance of a contract to which you are party or to take steps at your request before entering into such a contract​​ 

If applicable, to process and deliver your​​ order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity​​ 

(b) Contact​​ 

(c) Financial​​ 

(d) Transaction​​ 

(a)​​ Processing which is necessary for the performance of a contract to which you are party or to take steps at your request before entering into such a contract

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity​​ 

(b) Contact​​ 

(c) Profile​​ 

(d)​​ Marketing and Communications

(a)​​ Processing which is necessary for the performance of a contract to which you are party or to take steps at your request before entering into such a contract

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) ​​ 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity​​ 

(b) Contact​​ 

(c) Profile​​ 

(d) Usage​​ 

(e) Marketing and Communications​​ 

(f) Technical​​ 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)​​ 

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity​​ 

(b) Contact​​ 

(c) Technical​​ 

(d) Usage​​ 

(e) Profile​​ 

Necessary for our legitimate interests (to develop our products/services and grow our business)​​ 


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.​​ 

If you have consented to receive marketing, you may opt out at a later date.

Promotional offers from us​​ 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).​​ 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us​​ and, in each case, you have not opted out of receiving that marketing.

Third-party marketing​​ 

We will get your express opt-in consent before we share your personal data with any company outside​​ of Active​​ for marketing purposes.​​ 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by​​ contacting us​​ at any time.​​ 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of​​ any activities in relation to the performance of our contract with you.


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly

Change of purpose​​ 

We will only use your personal data for the purposes for which we collected it.​​ 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.​​ 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  • Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.​​ 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.​​ 

  • International transfers

We​​ may​​ transfer your personal data outside the European Economic Area (EEA).

Some of our external third party service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.


  • Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.​​ 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  • Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.​​ 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by​​ contacting us.

In some circumstances you can ask us to delete your data: see below for further information.

  • Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access​​ to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction​​ of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure​​ of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.​​ 

Object to processing​​ of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to​​ object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing​​ of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.​​ 

Request the transfer​​ of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time​​ where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If we have sought your consent and you later withdraw such consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.​​ 

If you wish to exercise any of the rights set out above, please​​ contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to​​ help clarify the scope of your request.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  • Glossary


Legitimate Interest​​ means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We​​ make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by​​ contacting us​​ 

Performance of Contract​​ means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation​​ means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.


Internal Third Parties

Other companies in the​​ wider​​ Active Payment Services​​ Group​​ or with​​ shared​​ common ownership act​​ as joint controllers or processors and are based​​ within​​ the European Union​​ and provide IT and system administration services and undertake leadership reporting.​​ 

External Third Parties

  • Service providers acting as processors based​​ in the European Union​​ who provide IT and system administration services.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based​​ in Europe​​ who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

  • Payment terminal and software providers to provide on going support in accordance with the terms of the contract.