Privacy and Cookies Policy.
MONEYGATE SOLUTIONS LIMITED respects your privacy and is committed to protecting your personal data. We correspond, apply or establish relations with us as a customer or partner and we process your data as a data controller.
1. IMPORTANT INFORMATION FOR THE PURPOSE OF THIS PRIVACY AND COOKIES POLICY
This Policy sets out current policies and commitment to data protection and privacy. The data that we collect and process is strictly necessary in the context of our relationship with potential clients, partners, users of our websites, applications, tablets and online resources in order to provide services and/ or information for specific and legitimate purposes.
This Policy is intended for those browsing/using http://www.moneygate.com, apply or establish relation with us as a customer and describes and explains how we treat personal data information that is received and/ or collected, when received or collected, through your use of Moneygate Solutions Ltd or our services. The Company protects the privacy and confidentiality of information in its possession and is committed to appropriate use and protection of personal data, with transparency and respect for rights in accordance with EU Regulation 2016/679 (GDPR) and applicable data protection legislation (the “ Data Protection Law”).
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy and Cookies Policy together with any other privacy notice we may provide on specific occasions when we are collecting and processing personal data as data controller about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. We make our Privacy Notice available on our website, www.moneygate.com. Please review it carefully. It contains information on how we collect, use, share and protect the personal data that we obtain.
MONEYGATE SOLUTIONS LIMITED is the controller and responsible for your personal data (collectively referred to as [the ”Company ”], “we”, “us” or “our” in this privacy notice).
The Company has appointed a Data Protection Officer, who can address questions and concerns and can be contacted as follows:
Our full details are:
Full name of legal entity: MONEYGATE SOLUTIONS LIMITED
Email address: firstname.lastname@example.org
RIGHT TO FILE A COMPLAINT
If you have any complaints about the use of your data, exercise of your rights, you have the right to notify and/ or file a complaint at any time to our DPO directly at the contact details indicated below for investigation.
You may also submit a complain to the Commissioner for Personal Data Protection, the Cypriot supervisory authority for data protection issues. Information on filing is available on the Commissioner’s website.
We would, however, appreciate the chance to deal with your concerns before you approach the Commission so please contact us in the first instance.
In this respect, complaints must be made in English in a comprehensive manner, and contain sufficient details and a clear description of the complaint. We will not be able to process requests which are incomprehensive or in languages other than English.
CHANGES TO THE PRIVACY AND COOKIES POLICY AND YOUR DUTY TO INFORM US OF CHANGES
The Company reserves the right to change this Policy from time to time with immediate effect and we will post an appropriate notification. In such a case, we make the most recent version of this Policy available on our website https://www.moneygate.com/cookie-policy-eu/ , informing you accordingly by displaying the update version and the relevant date of update.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS/ COOKIES
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and settings of these cookies and are not responsible for their privacy statements, therefore their data protection policies may differ from our Privacy Notice. When you leave our website, please ensure that you will check out the relevant policies of other entities are acceptable to you prior to using other sites or areas and how to manage them. Moneygate Solutions Limited does not accept any responsibility or liability for third party websites.
Inclusion of such links to third-party website, is for your convenience only and such inclusion does not imply affiliation, adoption by us. If we share information with third parties we shall do so in compliance with out Privacy and Cookies Policy. Third party products, services or sites may contain information or material that is illegal, unreasonable or that some people may find inappropriate or offensive.
The Company does not collect or store any personally identifiable information with cookies and do not combine cookie information with personally identifiable information in order to identify unique visitors.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes, first name, maiden name, last name, username or similar identifier, if you hold prominent public functions (PEPs), residence permit, title, date of birth and gender.
• Contact Data includes billing address, delivery address, home address, email address and telephone numbers.
• Financial Data includes bank account, income, assets, financial status, source of wealth, professional status, employment field, loans, credit reference information and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, including date, time amount, currencies, exchange range, beneficiary details, details of merchant or ATMs associated with the transaction, supplementary/supporting documentary evidence related to transactions details arising from contractual obligations between the Company and you.
• Technical Data includes internet protocol (IP) address, your geographical location details using GPS technology, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, IP address of sender and receiver.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Authentication data includes your signature specimens, biometric facial recognition, fingerprint(s).
• Documentary data includes details about you stored in documents in different formats or copies of them.
• Investigations data/ results of due diligence and enhanced due diligence includes due diligence checks, sanction and AML checks, information to identify and manage fraud, data regarding criminal conviction and offenses (special category data) as part of compliance measures with regulatory obligations.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
FAILURE TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you to provide you with our services.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including but not limited to:
• Direct interactions. You may give us your Identity, Contact and Financial Data etc by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• are opening an account
• create an account on our website;
• register to use the Moneygate app;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• give us feedback;
• correspond with us;
• in some cases, you may have previously provided your personal data to Moneygate Solutions Limited (e.g. the context of an existing or former Customer relationship)
• Third parties or publicly available sources. We may lawfully receive personal data about you from various third parties [and public sources] as set out below:
• Technical Data from the following parties:
(a) analytics providers [such as Google based outside the EU];
(b) advertising networks based inside OR outside the EU; and
(c) search information providers based inside OR outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU.
• Identity and Contact Data from data brokers or aggregators based inside OR outside the EU.
• Identity and Contact Data from publicly availably sources.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract and agreements we are about to enter or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where we have your consent by asking for specific permission to process personal information for specific purposes. In the case of specific permission provided by you, you may withdraw your consent any time. The revocation of your consent will not affect the legality of the data processed prior to the revocation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so, thus the type of data processed are strictly the data needed for lawful reason. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds, we are relying on to process your personal data where more than one ground has been set out in the table below:
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, only where this is required or permitted by law.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
You will receive marketing communications from us by post, email and phone (including text messages) with offers and promotions if you sign to our services and, in each case, you have not opted out of receiving that marketing.
We may use the information we have collected about you in order to tailor our offers and promotions to you.
We will not share your personal data with any company or organization outside the Company for our marketing purposes without your permission.
You can ask us or third parties to stop sending you marketing messages at any time by Contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Control of Cookies
If a User does not wish to receive cookies, he/she may be able to change the settings of the browser to refuse all cookies or to have the computer notify him/her each time a cookie is sent to it, and thereby give the choice whether to accept it or not. However, this may impair the quality of the Services that are being provided in relation to the trading account.
The Company shall not be liable for misuse or loss of personal data resulting from cookies on the Services that the Company does not have access to and/or control over.
Consent to Cookies
Types of Cookies
There are various types of Cookies needed to be used in order to enable the provision of the Services which include, inter alia, absolutely necessary cookies essential to enable navigation through the Services, performance cookies which are used to improve use of the Services, functionality cookies which are used to remember changes in choices a User requested and marketing cookies used to evaluate performance of advertisements and visits on the Services.
Cookies are typically divided into four main types, we may use some or all:
a. Strictly essential cookies: which are required for the operation of a website. For example, enabling uses to login to secure areas of website.
b. Analytical/ Performance cookies: which allow providers to recognize and count the total number of visitors and evaluate their navigation pattern around their website when they are using it.
c. Functionality cookies: which are used to recognize users when they return to our website and provide them with personalized content and preferences.
d. Targeting cookies: which record a user’s visit to a website, the individual pages visited and the links followed. If the cookie is set by a third party (for example, an advertising network) which also monitors traffic on other websites, this type of cookies may also be used to track a user’s movements across different website and to create profiles of their general online behaviour.
Some of the cookies on our website are session cookies which expire when you close your browser and are therefore not stored on your computer/device. Others are persistent and remain on your computer/device for an extended period and may be used for statistical purposes in order to track and target the location and interests of users that access our website (S) to enhance our marketing efforts.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Internal Third Parties being other companies connected with Moneygate Solutions Limited.
• External Third Parties being:
– Service providers acting as processors These service providers are required to provide sufficient assurances in accordance with data protection law. We will only share personal data necessary for them to provide their services.
– Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide professional services to Moneygate Solutions Limited.
– As such, personal data may be transferred and disclosed to:
– Money laundering and fraud prevention aggregation/agencies, compliance/verification services and risk prevention services. This is required in order to verify your identity, ensure protection against fraud, confirm eligibility for our services/products.
– Banks (other credit and financial service institutions), and similar institutions. These enable us to provide our services and include correspondent banks, intermediary banks.
– Payment Systems (SWIFT, SEPA, VISACard, JCB, Unionpay), payment service providers, card processing companies. These enable us to provide our services.
– Card manufacturing/personalization and delivery companies. In order for us to create a personalized payment card and deliver it to the requested address
– Data management, storage, archiving, cloud storage service providers
– Companies assisting us with provision of our services (e.g. technological services, solutions, support such as support/ maintenance/ development of IT applications, technology, website management, telephony/ SMS services)
– Customer support service providers and marketing service providers
– Administrative service providers
– Auditing and accounting services and consultants
– External legal advisors
–Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the Republic of Cyprus/ EEA/ Internationally who require reporting of processing activities in certain circumstances, such as:
Supervisory Authorities including the Central Bank of Cyprus, European Central Bank, European Banking Authority
– FIU (Financial Intelligence Units) and the Police
– Tax Authorities
– Information Exchange Mechanisms
– Other regulators, authorities and public bodies wherever obligations exist
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We do not anticipate to transfer your personal data outside the European Economic Area (EEA).
IF TRANSFERS OUT OF EEA OCCUR
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Given that the Internet is a global environment, using it to collect and process personal data and information involves the transmission of data on an international basis. By browsing our website and communicating electronically with us, you acknowledge and agree to our processing of personal data and information in this way.
7. DATA SECURITY
We have appropriate security measures in place to prevent unauthorized access to and protect the loss, misuse and alteration/ disclosure of the information under our control. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We utilize a series of technology and security solutions in order to protect data (such as storage of information you provide us on secure servers in the EEA, perimeter security mechanisms, such as encryption etc.). Nonetheless, security cannot be absolutely guaranteed against all threats despite our best efforts.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal data are available in our Retention Policy which you can request from us by Contacting us.
Under the Provision and Use of Payment Services and Access to Payment Systems Laws of 2018 and 2019 and Anti-Money Laundering laws we must keep records of you and your transactions for five (5) years.
In some circumstances you can ask us to delete your data: see paragraph 9. Your Legal Rights below for further information.
We will not keep records of your personal information for more than 6 years after our business relationship with you has ended unless a potential or ongoing claim or another legal reason occurs. You can refer to the Terms of Business
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request” “DSAR”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You cannot provide you with any information which is linked to an ongoing criminal or fraud investigation, or information which is linked to settlement negotiations with you. We will also not provide you with any communication between the Company and its legal advisers.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us through the app or send an email to the contact details provided for the DPO.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data and/or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You are responsible for ensuring that the information provided to Moneygate Solutions Limited by you/ about you or on your behalf is accurate and up to date, and you must inform us if anything changes as soon as possible.
If you provide information about another person, you must direct them to this Privacy Notice and ensure they also agree to Moneygate Solutions Limited using their information as described in it.
Should you have other questions or concerns about this Privacy and Cookies Policy please refer to the “Contact Us” tab https://www.moneygate.com/contact-us/ on our website.