All terms in capital letters that are not defined in this Policy shall have the meaning assigned to them in the Terms and Conditions by which You are also bound.
This Policy applies to any registered User or any potential user that has uploaded some data even without fully completing the registration process and opening an Account (hereinafter "You").
We remind You that the use of our Application is strictly prohibited to a User under the age of 18. We also retain this minimum age as the age of consent to the processing of Personal Data. Should You break this mandatory requirement, the Company rejects any claim of liability as it never knowingly intended or attempted to solicit or receive information from children.
2. Collecting the User's Personal Data
2.1. We may collect, receive and process any information, including Personal Data as defined below, when You register with the Application, create your Account, or during any action You perform on the Application, such as placing an order for the performance of a Transaction, or also when You communicate with us. In those events, you will be providing Personal Data.
2.2. We may also collect information through automatic means, for instance by using cookies, and We may also obtain data about You from third parties, notably in order to fulfill our legal obligation to prevent fraud and money laundering.
2.3. We may also collect information indirectly from other sources such as partners, banks or financial institutions from which We receive your funds, or social media platforms through which You may have connected to the Application.
2.4. "Personal Data" is defined as the data procured by the User in respect of himself and/or of the Recipient and comprises identification data which may include the place of residence, citizenship, birthdate, email address, phone number or any contact information, and all document uploaded in this respect, as well as all financial data related to the use of the Services such as the bank account details, the credit or debit card number, the amount and currency and frequency of Transactions, and also technical data such as IP address used device information, browser type, operating system or and GPS location from the used device, and derived data that would enable the profiling of the User or of the Recipient. The Personal Data shall not include anonymous data which will fall within the non-personal information type.
2.5. Our right to collect your Personal Data is based on:
2.5.1. Your express consent to such collection;
2.5.2. Any legitimate interest to process data, however not overriding your own rights and freedoms;
2.5.3. Any legal or regulatory requirement that imposes on us to collect Personal Data, notably but not only, the applicable regulations against money laundering and financing of terror;
2.5.4. The necessity and appropriateness to perform our obligations towards You.
2.6. The collection of your Personal Data also enables us to perform our Services and improve our customer services.
3. Use of the User's Personal Data
3.1. We may use your Personal Data to provide and improve our Services, to contact You about our Services and your Account, or for customers service purposes, or to detect, prevent, mitigate and investigate fraudulent or illegal activities. We also use this information for sending promotional communications with respect to services that may be of interest to You based on the information in our possession.
3.2. Please see the details of the following ways in which the Company may use the information collected, including your Personal Data:
3.2.1. To provide You with the requested Services and to fulfill our obligations to You or to other institutions in connection with the Services, including by sharing it to our affiliates or to third parties necessary to the performance of the Services;
3.2.2. To perform financial and identity checks, fraud prevention checks, anti-money laundering and credit checks, including examination of your request for Services according to legal regulatory requirements, risk management examination and fraud detection, whether by the Company itself or through third parties, and You give your irrevocable consent to it;
3.2.3. To provide reports that include the User's Personal Data to anti money laundering authorities, and to any other competent authority, regardless of the jurisdiction, in accordance with legal requirements and at the discretion of the Company, without any possible claim from the User against the Company in this respect;
3.2.4. To enforce our Terms and Conditions, as well as enforce our rights, privacy, safety or property, and/or that of You or of our affiliates, or of others.
3.2.5. To record and track details of transactions You carry out in relation with the Services, including the history of transactions performed and the recipients, including through databases of the Company and third parties, and credit card details provided by You, and You give your consent to such checks, in your name, in the name of the entity sending the funds if different from You, and in the name of the recipient, and You will have no claims in connection therewith.
3.2.6. To serve for the Company purposes, including among others, use of aggregated transactional information and anonymized information for commercial purposes - service and surveys, statistical data research and analysis, and using external companies which gather and analyze statistical information about use of the Application and Services and keeping track of your login name, passwords, and pages You may have visited on the Services; this use of aggregated and anonymized information would not allow a user identification to third parties;
3.2.7. To determine the patterns of use of the Application and to use such data in order to improve the Services on the Application, their operation and contents, and also for the purpose of delivering to the User marketing and/or other notices and updates, customizing the Application to the User himself or to all Users;
3.2.8. To improve the quality of the Services and customize your experience, and to the use and improvement of our customer service, including answering questions and responding to feedback and complaints;
3.2.9. To send communications, administrative or promotional e-mails or SMS or push ups via the Application and/or reaching You via social media platforms, with respect to Services that may be of your interest based on information in our possession. You may tell us at any time if You do not wish to receive marketing messages from us by contacting us at [ ] or by choosing to opt out of receiving additional promotional e-mails from us by clicking on the 'unsubscribe' link in any such e-mail, or by following any instructions Company may include in the message sent to You (the “Opt-out Request”). Please note that, once We receive such Opt-out Request, it may take an additional period of time for it to become effective. Note that, if You opt-out of our promotional communications, the Company may still communicate with You from time-to-time, if the Company needs to provide You with information or for other non-marketing reasons related to the Services.
Please be informed that no automated decisions or profiling are made in the course of the processing of your Personal Data.
4. Disclosing of information to third parties
4.1. We may share your Personal Data or any other non-personal information with third parties to provide You with access to our Services, with suppliers working on our behalf, where We have your permission, or where We are required or permitted to do so by law. We may also share your Personal Data or other non-personal information with third parties to comply with our legal obligations, to prevent any fraudulent or illegal activities related to our Services, to respond to legal process or to protect the rights or property of the Company, of our customers or of others. We attempt to minimize the amount of personal information We disclose to what is directly relevant and necessary to accomplish the specified purposes.
4.2. We will not disclose to third parties the Personal Data gathered about You via the Application and Services, inasmuch as this data identifies You personally, except notably in the cases set forth hereinafter:
4.2.1. To collect, hold and manage your Personal Data through Company's trusted service providers (including their sub-contractors) who apply suitable safeguards to protect the privacy and security of your Personal Data, for example, cloud computing platform and hosting services provider, as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as in your jurisdiction;
4.2.2. To partners and financial institutions that take part in the processing of the Services, including the credit institution where you maintain a bank account and any other financial institutions who may process your payments and our local partners that enable the provision of the Services to the recipients of the Transactions;
4.2.3. Risk management. We reserve our right to use trusted third parties to secure transaction processing and to conduct identity verification and preventive checks of fraud or of any other illegal activity or otherwise address security or technical issues (for example, World Check by Thomson Reuters for money laundering detection) and of bank transfer transaction, and We send Personal Data to those third parties;
4.2.4. To communicate with our customers about their account and provide customer support, including by way of our third-party trusted service providers;
4.2.5. To provide information to our authorized representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, security and other requirements;
4.2.6. To provide, support, and improve the Services We offer. This includes, for example, aggregating information of your use of the Services or Application and sharing this information with third parties to improve and support our Services and to make certain features of the Services available to You;
4.2.7. To your social media connection, if you connect your Application's account to your social media account.
4.2.8. To promote the use of our Services. Sharing your contact information with our trusted service providers that assist us in sending notifications, marketing, advertisements and customer service, including via social media platforms. You can stop receiving our promotional messages by following the unsubscribe instructions included in every notification or by contacting us at [ ].
4.2.9. To satisfy applicable laws and regulations, if and as applicable, including reports to Anti Money Laundering Authorities and to any other competent authority, in accordance with legal requirements, to financial institutions that take part in the processing of the services for compliance purposes, and to comply with a judicial proceeding, court order, or legal process;
4.2.10. To enforce the Terms and Conditions, including investigation of potential violations thereof, and to protect against harm to the rights, property or safety of the Company, its Users or the public as required or permitted by law;
4.2.11. Should the Company go through a business transition such as a merger, acquisition of all or a portion of the Company's assets, your Personal Data may be among the assets transferred and it will be transferred only subject to restrictions similar to those contained herein or as otherwise be required by applicable laws and regulations.
Please note that these third parties may be in other countries where the laws on processing Personal Data may be less stringent than in your country.
Except where permitted as stated, the Company does not sell, rent, share or otherwise disclose Personal Data to third parties. Nevertheless, the Company may transfer and disclose to third parties or otherwise use non-personal information at its own discretion.
5. Storing your Personal Data and external transfer
5.1. Your Personal Data may be transferred to, stored at and processed in a destination outside your territory and/or outside the European Economic Area ("EEA"), where your Personal Data may not be protected by the same standards. We endeavor to take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy, including the use of any adequacy mechanisms required by law to ensure that the transfer is lawful.
By using the Application and Services, You hereby agree to this transfer, storing or processing and waive any claim in this respect.
5.2. The reasons for such transfer, processing and storage outside the EEA are as follows:
5.2.1. Where our hosting service provider or cloud computing platform is outside your territory or outside the EEA.
5.2.2. Transfer to our affiliated companies or partners that is needed for providing the Services;
5.2.3. Where anti-fraud agencies, credit reference agencies and other service provider that are based outside your territory or outside the EEA, require access to your data to perform their obligations to us;
5.2.4. Where the processing is performed by staff operating outside your territory or outside the EEA working for us or for one of our service Providers. Such staff may be engaged in, among other things, the fulfillment of orders, the processing of payment details and support services in provision of the Services. Where such staff is acting on behalf of the Company, We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with applicable law and with this Policy.
5.3. Notwithstanding the above, You acknowledge that the request to perform a Transaction to a Recipient located outside your territory and outside the EEA constitutes per se conclusive evidence of your consent to transfer Personal Data to the country where the Recipient is located.
6. Data Retention
We may retain your Personal Data in conformity with applicable laws in order to comply with our legal requirements or to protect Company's legal interests, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce the Terms and Conditions and take other actions otherwise permitted by law. Beyond this retention period authorized by the applicable laws, your Personal Data will be deleted in accordance with our procedures.
In addition, Company will retain your Personal Data after your registration to the Services is cancelled, or if your application is declined or abandoned, for as long as permitted under any applicable law, for legal, regulatory, fraud and other financial crime prevention.
7.2. Cookies are alphanumeric identifiers that are transferred to and stored in your device through your web browser for record-keeping purposes. Some cookies allow making it easier for you to navigate, while others are used to enable a faster log-in process or to allow to track your activities.
7.3. When you access the Application, you will be presented with a message bar requesting your consent to set those cookies. By continuing to browse the Application You are enabling us place cookies on your device and/or our partners to provide a better experience and service to You.
7.4. The Application may place the following type of Cookies:
- Essential cookies: These cookies are necessary to allow you access and move around our Application and use all its features. Without these cookies, you would not be able to access our Application and/or to use certain important features.
- Visitor Cookie: These cookies are part of our security mechanism and are used to identify visitors (visitor representing a specific computer/phone device) of the Application,
- Analytics cookies: This Application also uses analytics cookies placed by Google Analytics (including Google Tag Manager) to measure the number of visits and the parts of the app that are the most popular among our Application visitors as well as for benchmarking purposes. This information is used to provide aggregated and statistical information on the use of this Application and is used to improve the contents of this Application to enhance your user experience. To opt-out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout/ (or to other Google link as may be updated from time to time)
- Advertising cookies: These third-party cookies, such as Google Adwords, help ensure that our advertisements are as relevant to you as possible. These cookies track and record information (including by Google) regarding your browsing habits and activity, and use this information to enable us to show you relevant/personalized marketing content across the Internet. Using these cookies, our third-party service providers may collect personally identifiable information (for instance when information collected by such cookies is associated with your Google Account) and use this to display our targeted advertising to You. For example, some advertising cookies help select advertisements that are based on your interests. You can opt out of Google’s use of the abovementioned cookies by visiting Google’s Ads Settings: https://adssettings.google.com/authenticated (or other Google link as may be updated from time to time).
You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed.
8. Third Party Services
8.1. Certain Services on the Application, such as services related to Facebook[D10] , are in fact managed by bodies other than the Company. In these cases, the Services are provided or operated not via the Company computers alone, but rather via the other bodies as stated.
8.2. The Company is entitled to be assisted by third parties, including advertising companies, for the purpose of presenting advertisements on the Application. It is possible that these parties use information about your online activity (which does not include identifying personal information), among others in order to provide advertisements for products and services which may interest You.
8.4. The Services may also contain links to third party websites and services, which are outside the Company's control and are not covered by this Policy. The Company does not assume responsibility for the privacy practices of such other applications or websites to which it may link, and encourages you to review those privacy policies yourself.
9. Security Precautions to protect your information
9.1. We take a great care in implementing and maintaining reasonable security procedures consistent with prevailing industry standards to protect the security of the Application, the Services, and our Users’ Personal Data or other information from accidental loss and from unauthorized access, use, alteration and disclosure.
9.2. We maintain procedural safeguards to try to prevent potential unauthorized access and misuse of the information that We process and store. Within our Company, We restrict the access to your Personal Data to those employees that are trained about the importance of confidentiality and privacy of customer information.
9.3. While We take reasonable precautions against possible security breaches of the Services, no application or internet transmission is completely secure, and We cannot guarantee (i) that unauthorized access, hacking, data loss, or other breaches shall never occur; and (ii) the security of your data while it is being transmitted to and from the Services; any transmission is at your own risk. The Company urges You to take steps to keep your Personal Data safe, including your Account password, and to log out of your Account after use.
9.4. You are responsible for keeping this password confidential and complying with our instructions. You must not share credentials with anyone else, and You authorize the Company to act upon instructions and information from any person that enters your credentials. You also agree to promptly notify us of any information you have provided to us which has changed or of any reason to suspect that your Personal Data has been compromised.
10. Terms and Conditions
Please also review the Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of the Services, available on the Application.
11. Your Privacy Rights
You may have certain rights under data protection legislation including the right to see the Personal Data held about You and You may ask us to make necessary changes to ensure that it is accurate and up to date. Where applicable, data protection legislation may also provide the following rights in relation to Personal Data:
- request us to give you access to it;
- request us to rectify inaccurate or incomplete information, or erase it, where applicable;
- request us to restrict or to stop our using it, in certain circumstances;
- withdraw your consent to our using it;
- data portability, in certain circumstances;
- opt out from our direct marketing, if applicable; and
- lodge a complaint with the relevant Data Protection Authority.
Dealing with the requests You may have in respect of your rights shall be in principle free of charge, however We reserve the right to charge a reasonable fee notably where the request appears to be manifestly unfounded or excessive, or burdensome, in particular because of its repetitive character, in which cases We may also choose to refuse to act.
The Company is entitled to verify, according to its procedures, the identity of each person sending a request before answering to it.
To proceed with a request, You may contact us as indicated in our Application.
12. Changes to our Policy
13. Contact us
If you have any additional questions or concerns about this Policy, please feel free to contact us any time through the Services as indicated in the Application and at the following [ ].