TERMS OF SERVICE PRIVACY POLICY

TERMS OF SERVICE

These terms and conditions govern the remittance service, including bill payment (hereinafter referred to as the "Service") provided by the company with the name "OTRO PAY ELECTRONIC MONEY INSTITUTION SINGLE-MEMBER SOCIETE ANONYME" headquartered in Athens, at 12 Neapoleos Street, (P.C. 15 123 Athens), with VAT number 801587027, and or which it is legally licensed from the Bank her Greece electronic money institution (Decisions of the Hellenic Financial Institutions Council No. 400/9/27.09.2021 and 497/1/21.03.2024, published in Government Gazette B/4610/6-10-2021 and B1987/1-4-2024 respectively)) pursuant to Law 4537/2018 and Law 4021/2011 (hereinafter the "Company»).

For their purposes of present terms the below words/ phrases will have the following sense:

DEFINITIONS
Agent The outlets of businesses contracted with the Company that provide the Service to Customers.
Receipt The document containing the essential transaction details regarding the Customer which is given to the Agent when the Service is completed and delivered to the Customer.
Transaction Number   An identifier assigned by the Company to the Customer immediately after completion of the Service, which the Customer can use to inquire about the payment status.
Payee  The natural or legal person who is the final recipient of the funds that are the subject of the transaction for which the Payment Order is given. Payees include, in particular, public organizations, businesses, the Hellenic State, legal entities under public law (NPDD), social security funds, telecommunications, electricity, and water supply companies, and other public or private sector entities, as well as any type of legal entity or business that has entered into a cooperation agreement with the Company under which the latter may accept payments on their behalf, including licensed betting service providers. The current list of Payment Recipients can be requested from the Customer Service Department. The Company reserves the right to amend the list.
Payment Order The instruction, given to the Company by the Customer, to transfer a specified amount of money in order to be made available to the Payee or transferred to an account held with a third-party payment service provider unrelated to the Company.
Transaction Fees The fees charged to the Customer for the provision of the Service. The Transaction Fees are communicated to the Customer by the Agent prior to the completion of the transaction. Specifically, for public sector bills, the fee is €1.50 per transaction, and for other bills, it is €1.00 per transaction.
Business Day Days on which banks are open and which are not officially recognized holidays in the local region or in the Eurozone.
Payment Code The code appearing on the bills issued by the Payee or on vouchers issued through the website or app of betting service providers. In order for the Service to be provided to the Customer, the Customer must have this code available.
Maximum Execution Deadline Payment Orders submitted after 14:00 to an Agent are executed on the next Business Day. Specifically, for Payment Orders relating to deposits into a gaming account held with a licensed betting company, the betting company is notified in real time of the payment of the Total Payment Amount and credits the Customer's gaming account in real time with an amount equal to the Payment Order Amount.
Customer The natural person (over 18 years old and with legal capacity) who visits an Agent to make a payment to a Payee. Specifically, for payments to betting companies, the Customer must be at least 21 years old.
Payment Order Amount The amount the Customer wishes to remit to the Payee.
Total Payment Amount The sum of the Payment Order Amount and the Transaction Fees that the Customer must pay to complete the transaction.
Customer Service Department The Company’s department that the Customer may contact for any matter related to the Service.
Service The payment service governed by these terms and conditions, which consists of the Customer paying a specific amount of money, either in cash or by card, to an Agent for the purpose of settling a bill issued by a Payee or transferring a specific amount to a Payee. The Service is considered a single payment transaction under Law 4537/2018 and qualifies as a money remittance service as defined in Article 4(22) of Law 4537/2018.

The Company provides the Service to Customers through its Agents. The Service is offered exclusively in euros (€).

  1. Service Procedure

The Customer visits an Agent and is asked to present the bill they wish to pay or to scan their Payment Code, and to provide a valid contact phone number to allow the Company to communicate with them—especially in cases requiring clarification or if the Payee rejects the payment. Next, the Customer is asked to present their ID card or passport, and is informed of the Transaction Fees, the Maximum Execution Time, and whether payment of the Total Payment Amount by card is possible. The Customer then places the Payment Order. Depending on the amount involved, the Agent may retain a copy of the Customer’s ID/passport. They may also request additional documents (e.g. utility bill confirming the Customer’s address, tax return, employer statement, etc.) to comply with the Company’s AML Policy—or where a transaction is reasonably deemed unusual or suspicious.

Once the Customer pays the Payment Order Amount and Transaction Fees in cash or by card (if it is accepted by the Agent), the Agent enters the Payment Order into the Company’s system.

After successful verification, the Customer is informed of the Payment Order’s submission, and upon completion, receives a receipt containing the Payment Recipient’s details, the Payment Order Amount, the Transaction Fees, the date and time of the transaction, the Payment Code and the Transaction Number.

By using the Transaction Number, the Customer can receive information regarding the Payment Order from the Company's Customer Service Department.

Note: Payment of a bill past its due date or partial bill payment is done at the Customer’s own risk and only if such options are permitted by the Payment Recipient.

2. Company Liability.

The Company is liable only for damages resulting from intentional misconduct or gross negligence by its staff or Agents. It bears no liability for minor negligence.
In any case, the Company’s liability is limited to the Total Payment Amount, which it must refund.

The Customer must ensure the accuracy, completeness and legibility of the information provided to the Company for the provision of the Service. The Company is not responsible if the payment is not completed because the Customer provided incorrect information. resulting in the rejection of the payment or if the Payee refusesthe payment for reasons outside the Company's control. The Company shall not be held liable for compensatory or consequential damages arising from delays or failure to complete the payment due to: (a) force majeure, including, but not limited to: total or partial suspension of Company or partner bank operations, strikes, wars, terrorist acts, declaration of a state of emergency, or other events beyond the Company’s control, (b) acts or omissions of partner credit institutions, (c) any other cause beyond the Company’s sphere of influence.

The Company and its Agents may refuse to provide the Service if there are reasonable suspicions of actual, intended, or potential criminal activity—especially fraud, money laundering, or terrorist financing—or for reasons of compliance with applicable law, court decisions, or demands from regulatory or governmental authorities.
Refusal may also occur if the Customer refuses to show valid ID or submit additional required documentation (e.g. utility bill) as mandated by current law.

3. Cancellation and refund

A Customer wishing to cancel a transaction may contact either the Agent who executed the transaction or call +30 2160020110.


Cancellation is only possibleif the payment to the Payee has not yet been completed and the Company has not yet transmitted the Payment Order to any cooperating credit institution. Payments to betting companies cannot be cancelled, as the Customer’s gaming account is credited in real time. To proceed with cancellation, the original Receipt issued for the transaction to be cancelled must be presented to either the Agent or the Company. Upon successful cancellation, the Company shall refund the Payment Order Amount to the Customer. Transaction Fees paid for the provision of the Service are non-refundable.


If the Payee ultimately does not accept the payment, the Company shall contact the Customer to refund the Payment Order Amount.

4. Resolution complaints

For any complaint, comment, or question,Customers may contact the Company’s Customer Service Department at +30 2160020110.


The Company will send the Customer a confirmation of receipt of the complaint within five (5) Business Days, which will include the date of receipt and a reference number to be used in all future communications regarding the same complaint.

The Company shall make every effort to respond to Customer complaints by email or in writing no later than fifteen (15) Business Days from receipt of the complaint. In exceptional circumstances, if a response cannot be provided within that period for reasons not attributable to the Company, a provisional reply shall be sent, clearly stating the reason for the delay and indicating the deadline by which the Customer will receive a final response. Under no circumstances shall this final deadline exceed thirty-five (35) Business Days from the receipt of the complaint.

The competent authority responsible for monitoring compliance with the applicable legislation (Law 4537/2018) is the General Secretariat for Commerce and Consumer Protection of the Ministry of Economy and Development (GGEPC).
The Customer retains the right to lodge a complaint with the GGEPC regarding alleged violations of the present Terms by the Company.

Where the Service is addressed to Customers in their capacity as consumers, competent bodies for the extrajudicial resolution of disputes between the Company and the Customer, as a payment service user, include: The Consumer Ombudsman (http://www.synigoroskatanaloti.gr/index.html ), the Greek Financial Mediator (https://hobis.gr/ ), the Alternative Dispute Resolution Center – ADR POINT IKE (https://www.adrpoint.gr/ ), the European Institute for Conflict Resolution (E.I.R.) (https://www.europeanresolution.com/ ) and the Institute for Alternative Dispute Resolution (startADR) (http://www.startadr.org/ ). For Customers who are not considered consumers and wish to settle a dispute amicably, it is recommended that they consult the above authorities in advance regarding their jurisdiction in each case.

5. Control transactions Additional information

Legislation prohibits payment institutions and electronic money institutions from cooperating with certain individuals and countries. The Company is obliged to closely monitor all transactions, comparing them against name lists provided by Greece, the European Union, and any other country in which it operates. In the event of a potential name match, the Company investigates the transaction to determine whether the name actually corresponds to an individual listed. From time to time, Customers may be requested to provide additional identity documents and information, in order to comply with the applicable legal framework.

6. Industrial and intellectual property rights

The Company and its Agents remain the exclusive holders of all rights to trademarks, trade names, software, and, more broadly, of all intellectual and industrial property rights, as well as all rights to tangible or intangible assets related to the Service.
The Customer shall not use the Company’s or its Agents’ logos, trademarks, trade names, or other distinctive signs without their prior written consent.

7. Personal Data

Company is processing the personally data of Customer with him way and for their purposes where are mentioned in Politics Protection Personal Data or which it is posted in the web page her Company www.otropay.gr

8. Other Terms

These terms have been drawn up in the Greek language and are governed by Greek law. The Greek courts it is competent for the resolution each difference about with the interpretation or the application of present These terms and conditions are available on the Company's website. www.otropay.gr The Customer accepts them. when gives the Mandate Payment. In each case the Customer has right to ask their terms them by the Company or by the Representative in hard copy without charge. The present terms are modified from the Company against times for to adapt in the current each time legislation or to reflect any changes in the way the Service is provided. The applicable terms are posted on the Company's website.

Part Service Customers: +30 2160020110, Monday until Friday hours 09:00 until 17:00, e-mail: info@otropay.gr , site: www.otropay.gr

Contact details for the Bank of Greece: street El. Venizelou no. 21, 10250, Athens, 210 3201111, www.bankofgreece.gr.

Personal data protection policy

At OTRO PAY we care about the protection of your personal data and want to be open and transparent about how we process it.

This Privacy Policy explains how we collect, process, and protect your personal data. It applies to visitors of our website, to our service points collaborating with us for bill payment services, and to consumers using our services.

The processing of personal data is carried out in accordance with the General Data Protection Regulation (GDPR – Regulation EU 2016/679), any specific national and European legislation applicable to certain sectors, the applicable Greek data protection law (Law 4624/2019) and the Law 3471/2006 on data protection and privacy in electronic communications, as well as the decisions of the Hellenic Data Protection Authority (HDPA).

DATA CONTROLLER

The Greek company "OTRO PAY ELECTRONIC MONEY INSTITUTION SINGLE MEMBER SOCIETE ANONYME", (hereinafter referred to as "OTRO PAY") is the controller of your personal data in accordance with applicable legislation.

  • Address: Neapoleos 12, Marousi, 15123, Greece
  • G.E.M.I. Number: 15964080100
  • VAT No.: 801587027
  • Tel.: +30 2160020110
  • Contact e-mail for personal data issues: gdpr@otropay.gr

WHERE IS YOUR DATA STORED?

The data we collect from you is stored within the European Economic Area (EEA).

Your rights

Access right:

You have the right to request information about your personal data held by us at any time. For this purpose you can send us an e-mail at: gdpr@otropay.gr

Right to portability:

Where OTRO PAY processes your personal data by automated means and the processing is based either on your consent or on a contract, you have the right to receive your data in a structured, commonly used and machine-readable format. You may also request that your data be transmitted directly to another controller. This right applies only to personal data you have provided to us.
To exercise this right, you can contact us at: gdpr@otropay.gr  gdpr@otropay.gr

Right to rectification:

You have the right to request the correction of your personal data if it is inaccurate or its completion if it is incomplete by sending an e-mail to: gdpr@otropay.gr

Right to erasure:

You have the right to request at any time the deletion of your personal data processed by OTRO PAY especially when:

  • Your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed
  • The processing of your data is based on your consent and you revoke this consent
  • Your data has been processed unlawfully.

The above right does not exist in particular when:

  • The processing of your data is necessary to establish, exercise or support legal claims
  • The processing of your data is necessary to comply with a legal obligation OTRO PAY which enforces the processing.

In any case, we will inform you of the satisfaction or non-satisfaction of your request and, in case of non-satisfaction, the reasons for this.

To exercise your right above you can send us an e-mail at: gdpr@otropay.gr

Right to object:

You have the right to object to the processing of your personal data based on OTRO PAY's legitimate interest. In this case, we will stop processing your personal data, unless we can demonstrate compelling legitimate grounds for the processing which override your rights and freedoms or for the establishment, exercise or defence of legal claims.

To exercise your right above you can send us an e-mail at: gdpr@otropay.gr

Right to object to direct marketing:

You have the right to object to the processing of your personal data for direct marketing purposes.

You can indicate your relevant wish in the following ways:

  • By following the instructions accompanying each e-mail with promotional content
  • By sending an e-mail to: gdpr@otropay.gr

Right of limitation:

You have the right to request the restriction of the processing of your personal data in the following cases:

  • When you dispute the accuracy of your personal data and up to OTRO PAY to verify their accuracy.
  • When the processing of your data is illegal and you object to its deletion, requesting instead the restriction of its use.
  • When the OTRO PAY no longer needs your personal data for the purposes of processing, but this data is necessary for the establishment, exercise or support of legal claims
  • When you object to the processing of your data by OTRO PAY which is based on a legitimate interest of the latter and until the existence of its illegitimate reasons is verified OTRO PAY that override your freedoms or rights.

To exercise your right above you can send us an e-mail at: gdpr@otropay.gr

Right to submit a complaint to the competent supervisory authority:

If you think that the OTRO PAY processes your data incorrectly, you can contact us at gdpr@otropay.gr or by phone at +30 2160020110.

You can also file a complaint with the Personal Data Protection Authority or any other competent supervisory authority.

Amendments to the Privacy Policy:

We may need to modify this policy. Its latest version Personal Data Protection Policy is always available on our website.

Contact form

Why do we use your personal data?

When you send a contact message to OTRO PAY through its website, OTRO PAY processes the data contained in said message for the purpose of fulfilling the request contained in your message.

What kind of data do we process?

We process your name, e-mail, telephone number and area of ​​residence/activity (if you choose to share this information with us). We also process any other personal data included in your message

In any case, you are encouraged not to disclose your personal data unless it is absolutely necessary to manage the request included in your message.

What is the legal basis for processing your data?

The legal basis for processing your data is your consent. You reserve the right to withdraw your consent at any time by sending an e-mail to: gdpr@otropay.gr. In this case, the legality of the processing based on consent before its withdrawal is not affected.

How long do we keep your personal data?

 OTRO PAY keeps your personal data for 6 months from the final settlement of the issue that is the subject of your message, unless there are legal or other reasons that require their retention for a longer period of time and until the said period has passed.

Newsletter

Why do we use your personal data?

We will process your personal data to send you newsletters by e-mail.

What kind of data do we process?

We will process your email address.

Who has access to your personal data?

Recipients of your personal data may be advertising agencies and technical providers for the dissemination of marketing messages.

What is the legal basis for processing your personal data?

Right to withdraw your consent at any time by sending an e-mail to: gdpr@otropay.grIn this case, the lawfulness of the processing based on consent before its withdrawal is not affected. You can also unsubscribe from our newsletter by selecting the relevant link contained in each of the messages sent to you.

How long do we keep your personal data?

We will retain your personal data for direct marketing purposes until you withdraw your consent.

Processing of personal data of cooperating points of provision of our services

The provisions of the Personal Data Protection Policy for Representatives apply to this processing.

Provision of the service

Why do we use the Customer's personal data?

When the Customer approaches an Agent and requests the payment of a bill or the sending of a transfer to a merchant who falls under the payment beneficiaries for whom OTRO PAY may collect funds or the sending of a transfer to a third party beneficiary, the Agent collects personal data the processing of which is necessary for the execution of the Payment Order.

In some cases, this information is transmitted to OTRO PAY by the merchant beneficiary of the payment to whom the Customer wishes to transfer a certain amount of money, after informing and/or (where applicable) obtaining consent from the Customer.

What kind of data do we process?

The legal basis for the processing of the Customer's data is the contract governed by these terms and concluded between the Company and the Customer each time they appear before an Agent to make use of the Service. The Customer, when requesting the provision of the Service, accepts the contract and agrees to the access, processing and retention of personal data necessary for the provision of payment services by the Company. In the case where there is a transfer of personal data from a Payee to OTRO PAY following receipt of the Customer’s consent, the Customer’s consent is the legal basis for said processing which consists in the transfer.

What is the legal basis for processing the Customer's data?

The legal basis for processing the Customer's data is the contract governed by these terms and concluded between the Company and the Customer each time he approaches a Representative in order to use the Service. When the Customer requests the provision of the Service, the Customer accepts the contract and agrees to the access, processing and retention of personal data necessary for the provision of payment services by the Company. In the event that personal data is transferred from a payee to OTRO PAY following consent from the Customer, the Customer's consent is the legal basis for such processing consisting in the transfer. 

To whom do we transmit the Customer’s personal data?


The Customer's personal data is normally collected by the Agents, who act as data processors on behalf of the Company.

Recipients of the personal data may be the credit institution cooperating with the Company, to the extent required for the execution of the Payment Order, the possible payment service provider of the Payee, the Payee, the Company’s legal and tax advisors, the competent tax authorities, the Bank of Greece and any other competent supervisory authority, within the framework of any audit conducted by it, as well as the Company’s technological providers (who act as data processors on behalf of the Company).


Payees and the payment service providers with whom they cooperate, the competent tax authorities, the Bank of Greece and any other competent supervisory authority act as independent data controllers, and the Company bears no responsibility for the processing of the Customer’s personal data carried out by them.

For how long do we retain the personal data?


The Company retains the personal data for a period of five years from the execution of the Payment Order or for a longer period, provided that this is required by applicable law or is necessary for the legal defense of the Company’s claims.

Responses to requests, inquiries, complaints


Why do we use the Customer's personal data?

When a Customer contacts the Company’s Customer Service Department and submits a complaint, request, or inquiry regarding the provision of the Service or a Payment Order, the Company collects and/or processes the personal data necessary to satisfy the Customer’s inquiry, request, or complaint.

What kind of data do we process?

We process the Customer’s full name, the Document Number, the details of any Receipt, such as the Payment Order Amount, the Transaction Fees, the date and time of the transaction, and the Payment Code, as well as any other identifying information the Customer chooses to disclose to us. In any case, the Customer is encouraged not to disclose personal information except to the extent necessary to satisfy their request or complaint.

What is the legal basis for processing the Customer's data?

The legal basis for processing the Customer’s data is their consent or, as the case may be, OTRO PAY’s legal obligation to respond to its customers’ complaints.

To whom do we transmit the Customer’s personal data?


The Customer’s personal data collected for the above purpose are not normally transmitted to third parties except when this is absolutely necessary to satisfy the Customer’s request, complaint, or inquiry. In the latter case, the Customer’s personal data may be transmitted to the Agents, as well as to the Company’s legal or tax advisors.

For how long do we retain the personal data?


In the event that the Company has reasonable suspicions that a transaction may constitute or be used to commit fraud, money laundering and financing of terrorism or other criminal activity, the Company processes the Customer’s personal data for the purpose of detecting, preventing, deterring, or suppressing criminal activity.
In addition, the Company processes, during the provision of its services to Customers, their personal data for reasons of compliance with the legislation on the prevention and suppression of money laundering and financing of terrorism or other criminal activity.


Prevention and suppression of money laundering and the financing of terrorism or other criminal activity – Detection and combating fraud and other illegal activities

Why do we use the Customer's personal data?

In case the Company has reasonable suspicions that a transaction may constitute or be used to commit fraud, money laundering and terrorist financing or other criminal activity, the Company processes the Customer's personal data for the purpose of detecting, preventing, deterring or suppressing criminal activity. Also, the Company processes the Customer's personal data when providing services to the Customer for the purposes of compliance with the legislation on the prevention and suppression of money laundering and terrorist financing or other criminal activity.

In certain cases, the required personal data are transmitted to OTRO PAY by the Payee to whom the Customer wishes to remit a certain amount of money, following notification and/or (as the case may be) receipt of consent from the Customer. 

What kind of data do we process?

We process the Customer’s full name, father’s name, telephone number/e-mail, as well as the Payment Code, the Customer’s identity card/passport number, their nationality, their place and date of birth.
We may also process data related to the profession, the residential address, the Customer’s income and its source, as well as other elements of the Customer’s financial status, the Customer’s TIN, the full name of the Payee (if a natural person), the inclusion of the Customer in lists of adverse publicity, lists of persons or entities subject to restrictive measures, issued under relevant regulations of the European Union or Decisions of the United Nations Security Council, as well as the corresponding lists of the Bank of Greece and the competent police, administrative and judicial authorities, or the fact that the Customer is or is associated with a Politically Exposed Person.

What is the legal basis for processing the Customer's data?

The legal basis for processing the Customer’s data is the obligation to comply with applicable legislation on the prevention and combating of fraud, money laundering and financing of terrorism or other criminal activity. In the event that personal data are transmitted by a Payee to OTRO PAY following receipt of consent from the Customer, the Customer’s consent is the legal basis for said processing consisting of the transmission. 

To whom do we transmit the Customer’s personal data?


The Customer’s personal data are transmitted to the competent judicial, prosecutorial, auditing and law enforcement authorities, including the Bank of Greece, as well as to the Company’s technological providers (who act as data processors on behalf of the Company).

For how long do we retain the personal data?


The Company retains the personal data for a period of 5 years from the execution of the transaction, unless their retention is required for a longer period in accordance with the instructions of the competent authorities or the applicable legislation.

Draft date: 21/1/2022

Last modified date: 15/7/2025

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