Date: 15. November 2019
This policy explains what you can expect from us with respect to your personal information and what we need from you. Please read this policy carefully as it is legally binding when you use our services.
1. How we protect your personal information
1.1 We take the security of your personal information very seriously and use a secure server to store your personal information.
1.2 As you know, the transmission of information over the Internet is not completely secure. Although we will make every effort to protect your personal information, we cannot guarantee the security of your information during transmission. Every data transfer is at your own risk. Once we have received your information, we apply strict procedures and security features to prevent unauthorized access.
1.3 We restrict access to your personal information to those employees who need to know the information for business reasons. We constantly train and educate our employees on the importance of confidentiality and protection of our customer data. We maintain physical, electronic and procedural security measures that comply with relevant laws and regulations to protect your personal information from unauthorized access.
1.4 For the purposes of providing our services, we may share your personal information with our affiliates.
2. Information that we may collect from you
If necessary, we will collect the following data about you:
2.1 Information you provide to us.
(a) You may provide us with personal information when you use our services, such as when you provide us with your personal information such as your name and email address. This includes information that you provide as part of your continued use of our services or when you notify us of a problem with our services. The information you provide may be: Your name, address, e-mail address and telephone number, date and place of birth.
(b) We may also request additional information from you to identify you, e.g. an identification document (identity card, passport) and a proof of address (consumption invoice) in the course of a legitimation check.
2.2 Information we collect about you. In connection with your use of our services, we may automatically collect the following information about you:
(a) Technical information, including the Internet Protocol (IP) address by which your computer was connected to the Internet, the type and version of browser, time zone setting, browser plug-in type and version, operating system and platform; as well as
(b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); Page response times, download errors, duration of visits to different pages, information about the interaction on specific pages (e.g., pages visited, pages viewed, etc.). B. Scrolling, Clicks and Mouseovers) and methods to leave a page.
2.3 Information we receive from other sources. We may receive information about you when you visit other websites operated by us or use other services offered by us. Banks and payment providers that you use to transfer money to us will provide us with basic personal information about you, such as Your name and financial information such as your bank account details.
3. Use of the data
We will use your information in the following ways:
(a) for fulfilling our obligations under any contract entered into between you and us and for providing the information, products and services you have requested from us;
(b) in order to comply with the relevant legal and official requirements;
(c) to notify you of any changes to our services;
(d) as part of our efforts to protect and secure our services;
(e) for the administration of our services and internal operations, including troubleshooting, data analysis, testing and research, as well as statistics and surveys;
(f) to improve our services and to ensure that they are presented to you in the most effective manner possible;
(g) to enable you to participate in interaction opportunities with our services if you choose to use them;
(h) for providing information about other similar goods and services that we offer;
(j) for merging information that you provide to us with the information we collect about you. We may use this information and the aggregated information for the purposes set out above (depending on the type of information we receive).
4. Disclosure of your information
4.1 We may share your information with selected third parties, including:
(a) Affiliated companies, business partners, service providers and subcontractors for the execution of contracts we enter into with such third parties or with you;
(b) Providers of analytics and search engines who support us in improving and optimizing our website; and
4.2 We may disclose your personal information to third parties in the following cases:
(a) in the event that we sell or purchase a business or asset, we may disclose your personal information to the prospective buyer or seller of such business or asset;
(c) to assist us in conducting and participating in investigations relating to fraud or other illegal activities where we believe it is reasonable and appropriate to do so;
(d) to prevent and prevent fraud and crime;
(e) in response to a subpoena, arrest warrant, court order or other statutory requirement;
(f) access to and assessment of financial and underwriting risks;
(g) to settle debts or in the course of insolvency proceedings on your part; and
(h) to develop customer relationships, services and systems.
5. Where we store your personal data
6. Disclosure of your data
6.1 In order to be able to offer our services, we sometimes need to pass on your data to mentioned third parties. In such cases, we will ensure that both we and our partners take adequate and appropriate technical, physical and organizational security measures to protect your information. We also ensure that appropriate contractual safeguards are in place with the aforementioned third parties.
7. Profiling and automated decision making (ADM)
7.1 We reserve the right to use parts of your data in order to individualise our services and the information we provide to you and to adapt them to your needs - for example regarding your country of residence or your transfer history. If, for example, you have If you frequently transfer money on a particular currency route, we may use this information to notify you of product updates to that currency route or other related updates or features. When we do this, we take all necessary steps to ensure that your privacy and security is guaranteed - and wherever possible, we only use pseudonymised data. This activity has no legal effect for you.
7.2 As an innovative technology company, we reserve the right to use automated decision making (ADM) to improve your user experience and combat financial crime. For example, we can use ADM to verify your identity documents faster and more efficiently or to confirm the accuracy of the information you provide. None of the ADM processes we use have any legal effect for you.
8. data retention
8.1 Depending on your jurisdiction, we may be required by law to retain some of your personal and transfer data even after our service to you has been completed. Your data will only be viewed or processed internally and according to the "need-to-know principle", i.e. only if absolutely necessary.
8.2 If the storage of data is no longer required by the applicable laws in the jurisdictions in which we operate, we will always delete the data.
9. your rights
9.1 You have the right to correct any personal information that is inaccurate, incorrect or out of date.
9.2 You have the right to ask us to delete your data if the retention is no longer necessary or is no longer part of a legal obligation to which we are subject.
9.3 From time to time, our services may include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites each have their own privacy policies and that we assume no responsibility or liability for these policies. Please review the applicable policies before submitting any personal information to these Web sites.