Personal data – To fight fraud

Information relating to your transaction is subject to automated data processing by Oneytrust, the data controller, with the aim of reinforcing the level of security of transactions recorded by the partner and protecting the partner and its customers against possible identity theft or attempted fraud.

Transactions carried out online or in a physical shop using a payment method that presents a risk of fraud similar to an online transaction require a sufficient level of trust to exist between the contracting parties. Oneytrust helps to assess this level of trust by providing a decision-making tool. The aim of this service is to ensure that the identity used in the transaction is genuine by minimising checks in order to simplify and speed up consideration of your request. In the event of proven fraud, this service may result in your inclusion in a file of persons at risk (watch list).


Your data is used by Oneytrust exclusively for the purposes of the aforementioned service, for which all detailed information is provided in this document. In the event of suspected fraud following the first stage of verification, this data may be subject to additional checks by Oneytrust, where appropriate with the support of its service providers, so as to avoid, as far as possible, the implementation of additional checks such as the verification of your proof of identity and address. The reliability of the data that you have transmitted for the purposes of the operation may in this context be checked by cross-referencing your data with that of Oneytrust or its service providers.

Purpose of the processing of data

Purposes

The purpose of the processing implemented by Oneytrust is to combat identity and payment/refund fraud in respect of transactions carried out remotely via the Internet or in a physical shop using a payment method presenting a risk of fraud similar to an online transaction.
It enables Oneytrust to:

  • analyse the data from the operation;
  • deliver a progressive assessment at different stages of the customer’s journey on the partner’s site(s), in order to guide the end customer’s subsequent journey accordingly;
  • provide an initial level of confidence, in particular by comparing the information on the transaction analysed with the information contained in the transactions carried out with Oneytrust’s various partners, thus detecting any inconsistencies based on pre-established rules, and assigning an evaluation (score) to each transaction carried out on the partner platforms; once the transaction has been validated by the customer and sent for analysis, provide the partner with a confidence index for the transaction in the form of a score between zero (0) and one hundred (100) depending on the level of risk assessed;
  • to determine, if the person concerned has consented, the machine identifier of the terminal (computer, smartphone, tablet, etc.) used by the said person to browse the partner’s site(s), in particular to check that the same terminal has not been used to carry out several transactions on the basis of different identities;
  • retrieve additional information from Oneytrust’s service providers to enrich and qualify certain transaction data (e-mail address, telephone, postal address, IP address, BIN 6);
  • according to pre-established rules, reduce manual reviews by automatically validating transactions that could not be validated by an automatic analysis device (automatic score);
  • detect attempted fraud when transactions are carried out via the Internet or in a physical shop using a payment method that presents a similar risk of fraud to an online transaction, and register customers who have committed proven fraud on a file of people at risk (watch list);
  • to carry out research or experimental phases in order to improve and enhance its solutions so that they are ever more relevant and appropriate, in order to protect consumers by continually improving the system for combating fraud; to this end, the data may be reused to train AI models.

Your data may be annotated (assigned one or more characteristics) by Oneytrust in order to identify the categories of data in the dataset.


Any irregular declaration or anomaly may result in the registration of the data relating to the transaction associated with this irregular declaration or anomaly on a watch list set up by Oneytrust.

Legal basis

Article 6 (1) f of the General Data Protection Regulation.
The processing is necessary for the purposes of the legitimate interests pursued by Oneytrust; namely, the fight against identity and payment fraud during remote transactions carried out via the Internet or in a physical shop with a payment method presenting a risk of fraud similar to an online transaction.


The collection of information from the terminal used to determine the machine identifier is a function of the Oneytrust service which requires the consent of the person concerned (article 82 of the amended law of 6 January 1978).

Data processed

Categories of data processed

  • Identification data: title, surname, first name, date of birth, e-mail address, postal address, telephone number, fax number, customer ID, NIF depending on the country of the transaction, proof of identity or K-bis extract, proof of address.
  • Economic and financial information: Bank card number (PAN) hashed, expiry date, first 6 and/or last 4 digits of bank card, IBAN, RIB, proof of income.
  • Connection data: IP address, fingerprint calculated from the technical data of the terminal used (operating system, language, resolution, browser type and version, etc.).
  • Transaction data: Delivery method, payment method, name of carrier, address of collection point or other delivery location, transaction reference amount and currency, date and time of transaction, number of products purchased, list of products, quantity per product, unit price of product, number of purchases, cumulative amount of purchases, date and time of first and last order.
  • Other categories of data: Confidence index, technical sub-elements for validating identification data, IP address and BIN6 by correlation (validity, associated identity, supplier, operator, etc.).

Data source

The information is collected from the person concerned via the partner, but also from Oneytrust’s service providers for additional data and from publicly accessible databases.

Obligatory nature of data collection

The non-transmission of data relating to your transaction prevents its analysis by Oneytrust. The execution of your transaction is solely at the discretion of Oneytrust’s partner.

You may refuse to give your consent to the collection of data used to calculate your terminal’s machine identifier and continue browsing. Terminal data is not collected in the absence of your consent, and this has no impact on browsing and the completion of the planned transaction.

Automatic decision making

The solution offered by Oneytrust to its partners is a decision-making tool that determines a level of confidence linked to the transactions recorded by the partner. The system has been developed to allow manual analyses to be carried out if necessary when the confidence index is drawn up, based on the automated data processing implemented by Oneytrust. Whatever the recommendation issued by Oneytrust, the partner is the sole decision-maker as to the follow-up to be given to the operation. Oneytrust does not intervene in the partner’s final decision.

The processing implemented by Oneytrust does not provide for refusal decisions based exclusively on automated analysis. In the event of a refusal decision being taken by the partner, based solely on Oneytrust’s recommendations, the data subject has the right to ask Oneytrust for human intervention, to make observations and to request a re-examination of his or her situation with regard to the processing carried out by Oneytrust.

People concerned

Data processing concerns:

  • natural and legal persons who carry out transactions at physical points of sale or via distance selling with Oneytrust’s partners;
  • authorised Oneytrust personnel responsible for the implementation of processing.

Data recipients

Recipient categories

According to their respective requirements, the following are the recipients of data, in whole or in part:

  • authorised personnel of Oneytrust ;
  • Oneytrust’s partner with whom the customer has carried out the operation; the latter receives, in particular, the results of the processing carried out by Oneytrust in accordance with the present document.
  • Oneytrust’s subcontractors and service providers; in particular, those to whom Oneytrust sends all or part of the data for verification, hosting and the supply of additional data. It being understood that these service providers are contractually bound to protect the personal data transmitted to them in this context.

Transfer of data outside the EU

Your data is stored within the European Union.

Oneytrust may use service providers located outside the European Union who may remotely access the data for specific services. These transfers may only be carried out after Oneytrust has taken the appropriate security measures, for example by ensuring the conclusion of standard clauses defined by the European Commission in order to control data flows.

In order to determine the machine identifier of the terminal used to browse the partner’s site(s), Oneytrust uses a service provider located in the USA who can remotely access the data collected associated with your terminal. The transfer of data is governed by the European Commission’s Standard Contractual Clauses and by additional measures to ensure effective data protection during the transfer.

On request, we can provide you with the names of recipients established outside the European Union and a copy of the specific conditions agreed in order to guarantee an appropriate level of data protection. If you wish to make such a request, please write to the Oneytrust DPO, whose contact details are given below.

Data retention period

The data is kept for a period of :

  • 37 months;
  • 15 months for supporting documents and the footprint calculated from the terminal’s technical data;
  • 6 months for consumption data.

Data relating to transactions for which fraud has been detected is entered on a watch list for a period of 2 years or until the payment incident is rectified if this occurs before the 2-year period expires.

The technical sub-elements used to validate the identification data, IP address and BIN6 (validity, associated identity, supplier, operator, etc.) will be kept for a period of 15 days.

Your rights concerning your personal data

In accordance with the applicable Regulations, you may exercise the rights set out below:

  • Right of access in order to obtain a copy of all the data processed by Oneytrust as well as information relating to the characteristics of the processing carried out on your data.
  • Right of rectification in order to update your erroneous and/or incomplete data.
  • Right to erasure if the data (i) is no longer necessary for the purposes for which it was collected, (ii) is processed unlawfully or (iii) if you exercise your right to object to the processing concerned. However, this right does not apply where the retention of your data is necessary for Oneytrust to comply with a legal obligation or for the exercise of legal claims.
  • Right to restrict processing where (i) you dispute the accuracy of the data, (ii) you exercise your right to object. Oneytrust will restrict the processing of your data for such time as is necessary for Oneytrust to carry out appropriate checks.
  • Right to object to your data being used by Oneytrust for its legitimate interests. Oneytrust will then cease such processing unless it can justify that its legitimate and overriding interests take precedence over your rights and freedoms.
  • Right to define general and specific directives setting out how you wish the above rights to be exercised after your death.

Exercising your rights

The Oneytrust Data Protection Officer (DPO) is your contact for any request to exercise your rights regarding processing.

  • Contact the DPO by email on dpo[at]oneytrust.com* *(replace [at] with @ when sending the request)
  • Contact the DPO by post

The Data Protection Officer
Oneytrust
34 avenue de Flandre
59170 Croix
FRANCE

Complaints

You can send in a complaint relating to the processing of your requests by Oneytrust by writing to the DPO. The latter will make every effort to reply to every complaint and endeavour to resolve the problem.
If, after contacting us, you consider your rights have not been respected, you can send a complaint to your local personal data protection authority or to the Oneytrust data protection authority, that is to say, the CNIL – 3 place de Fontenoy – TSA 80715 – 75334 Paris cedex 07.