Payment service providers are usually not processors
Characteristic of an order processing is that the processor may only process personal data on and within the scope of the ordering party’s instructions. This does not apply to payment service providers. Although they may be instructed to transfer a certain amount of money, they are not subject to any data protection instructions vis-à-vis the client. Furthermore, it should be noted that the customer also has a contractual relationship with the payment service provider – a unilateral obligation to the seller would therefore not do justice to reality. Rather, the payment service provider also acts on the basis of a contract with the customer who orders the payment. The payment service provider thus represents itself as an independent third party, which does not act on the instructions of the selling company, but processes data under its own responsibility. Also according to BayLDA, banks for money transfers and payment service providers are