Privacy Policy

Effective date: July 16th, 2025

Qombo SAS ("Qombo", "we", "our", or "us") is committed to protecting your personal data and respecting your privacy.

This Privacy Policy explains how we collect, use, store and share personal data when you interact with our website (https://www.qombo.tech) and use our services, particularly our fraud prevention and account verification solutions for payment service providers (PSPs) in the European Union.

We operate in full compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1. About Us

Qombo is a French company registered under number 929 940 237 with its registered office at 292 avenue du Prado, 13008 Marseille, France.

We provide a cloud-based Verification of Payee (VoP) solution for financial institutions. Our services help PSPs verify the consistency between a beneficiary and an IBAN before a payment is executed, in order to prevent authorized push payment (APP) fraud and improve trust in payments.

2. What Data We Collect

We may collect the following categories of personal data:

Professional identity and contact data: names, email addresses, roles, and credentials of our customers’ employees.
Service usage data: logs, metadata and API call information (e.g., timestamp, IP, identifiers) when accessing the VoP platform.
Bank account-related data: IBAN and beneficiary name pairs submitted by our clients for verification purposes.

We do not collect any sensitive data (within the meaning of Article 9 of the GDPR).

3. How We Use Your Data

We process personal data for the following purposes:

To provide and maintain our Anti-fraud Solution;
To secure our platform and detect fraudulent use;
To ensure compliance with European regulations;
To improve our services based on aggregate and anonymized statistics;
To fulfill our contractual and legal obligations.

4. Legal Basis for Processing

We process your personal data based on the following lawful bases:

Contract performance (Article 6(1)(b) GDPR): when you or your organization use our services.
Legal obligation (Article 6(1)(c)): for regulatory compliance.
Legitimate interests (Article 6(1)(f)): for fraud prevention, platform security, service improvement and client support.

5. Data Sharing and Transfers

We may share your personal data with:

Our cloud service providers, who host and maintain our platform in the EEA;
Third-party PSPs, only to the extent required to perform a bank account verification;
Supervisory authorities, when legally required.

We do not transfer personal data outside the European Economic Area.

6. Data Security

Qombo applies strict technical and organizational measures to ensure data protection:

Encrypted transmission (HTTPS / TLS)
Access control and audit logging
Data minimization and strict separation of client environments
Backup and recovery protocols

7. Data Retention

We retain personal data only for the time strictly necessary to fulfill the purposes described above, or as required by law.

IBAN-name pairs are pseudonymized and processed only for the duration of the verification process. Aggregated results may be stored for fraud pattern detection and audit logs, in accordance with legal retention obligations.

8. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

Right to access
Right to rectification
Right to erasure (“right to be forgotten”)
Right to restriction of processing
Right to object
Right to data portability
Right to lodge a complaint with the CNIL (France’s data protection authority)

To exercise your rights, please contact: dpo@qombo.tech

9. Cookies

Our website uses essential cookies to ensure secure navigation and platform availability. We do not use cookies for advertising or tracking purposes. You can manage your cookie preferences through your browser settings.

10. Changes to this Policy

This Privacy Policy may be updated from time to time. The updated version will be published on this page with a revised “Effective date”. We encourage you to review it periodically.

11. Contact

For any questions or concerns about this Privacy Policy or your personal data:

dpo@qombo.tech

Qombo SAS – 292 avenue du Prado, 13008 Marseille, France