Last modified on July 23, 2020
What Type of Information We Collect
How Do We Use the Information
How We Share the Information and For What Purpose
How Long Do We Retain the Information
How We Protect Your Information
Links to Third Party Sites
Policy Updates and Notifications
We will not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. However, in order for us to offer our services to our users; enhance the quality of our service from time to time; and protect the interests of our users, we will in limited circumstances share some of your personal information with third parties under strict restrictions, as described in more detail in this Policy.
2. WHAT TYPE OF INFORMATION WE COLLECT
We may collect two types of data and information from you.
The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services (“Non-personal Information”). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is information of an anonymous nature, such as an Internet Protocol Address (IP Address) provided it has been stripped of personal information, the domain used to access the Services, and the type and version of browser or operating system being used by visitors to the website. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, and average time spent on the Services is not considered Personal Information.
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal identifiable information, such as your name, e-mail address, physical address, date of birth, phone number, and photo ID. At the time of collection, we will clearly identify the information being collected. It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information, in some instances you may not be able to register to use the Services or be able to access and use the Services at all. In other instances, your choice not to provide certain other Personal Information may mean that you will not be able to use certain features of the Services. We may collect Personal Information in respect of the Services through service purchases; communications with you, transaction and user authentication procedures, user support; and surveys.
Such information may include:
Basic Service: When you use our Services, we ask you to provide Personal Information related to that transaction such as, but not limited to, your name, mobile phone number, email address, physical address, wallet address, proof of identification and other payment information. In general, none of your information will be shared with any other users of our Services. Using certain profile information, we may utilize third parties to extract additional information to help verify the authenticity, and any background checks required on your profile, including such information as the amount of the transaction, the type of transaction and payment information.
Communication Information: We may collect information from your communications with us. For example, when you communicate with us, or respond to communications from us, via email, chat, audio or video calls (“Communications”). We may record and keep all the Communications.
Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers, as well as other information which relates to your activity through the Services.
For avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.
3. HOW DO WE USE THE INFORMATION
We aim to collect, use and disclose only such information as is required to enable us to provide the Services, including verifying identification and authenticating transactions, to maintain transaction histories and customer lists, to respond to your inquiries or provide feedback, for identification and authentication purposes, and for service improvement. We will maintain the confidentiality of any Personal Information you provide to us on signing up for our Services or contacting us with questions or for further information and we will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties.
To set up your account and to provide the Services;
To identify and authenticate your access to certain features of the Services;
Resolve disputes, collect fees, and troubleshoot problems;
Inform you about service updates and faults;
Investigate and prevent potentially prohibited or illegal activities, and enforce our Terms of Service;
Customise, measure, and improve our services and the content and layout of our website;
Deliver targeted marketing and advertising, service updates, and promotional offers;
Compare information for accuracy, and verify it with third parties;
For our internal purposes, to associate relationships amongst our users and transactions through such attributes as name, mobile number or device information to comply with anti-money laundering and anti-terrorist financing laws and regulations.
Protect your and our interests, including in particular to enforce our Terms of Service and investigate, prevent and fight against fraud; and
Comply with legal and regulatory requirements.
4. HOW WE SHARE THE INFORMATION AND FOR WHAT PURPOSE
Disclosure to Third Parties Other Than Our Users
We will not sell or rent any of your personal information to third parties for their marketing purposes without your explicit consent, and will only disclose this information in the limited circumstances and for the purposes described in this Policy. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
Specifically, you consent to and direct us (and third party service providers acting strictly on our behalf) to do any and all of the following:
Disclose information including, without limitation, transaction information, account information, personal information and the contents of communications to: the police; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies (other than tax related authorities), departments, regulatory authorities, self-regulatory authorities or organizations; and other third parties that we in good faith believe it is appropriate for us to cooperate with in investigations of fraud or other illegal activity or potential illegal activity, or to conduct investigations of violations of our Terms of Service (including without limitation, your funding source or credit or debit card provider). If you provide false or inaccurate information and fraud is identified, we may pass details to fraud prevention agencies and law enforcement agencies may access and use that information. We and other organizations may also access and use this information (including information from other countries) to prevent fraud and money laundering.
Disclose information in response to the requirements of the credit card associations or a civil or criminal legal process.
Disclose necessary information to the payment processors, banks, credit card associations, or other service providers necessary to provide the Services you request (these third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information was shared).
Disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian legally appointed for you).
Disclose aggregated statistical data with our business partners. For example, we may disclose that a specific percentage of our users live in particular geographies. However, this aggregated information is not tied to Personal Information.
Cookies and How Do We Use Them?
We use analytics software to allow us to better understand the functionality of our software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile app.
5. HOW LONG DO WE RETAIN THE INFORMATION
We retain the information we collect for as long as needed to provide the Services (including aspects of risk management) and to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements (unless we are instructed otherwise). We may rectify, replenish, or remove incomplete or inaccurate information at any time and at our own discretion.
6. HOW WE PROTECT YOUR INFORMATION
We take great care implementing and maintaining the security of the Services and your information. We aspire to continuously employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information.
We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you. We will take appropriate organizational and technical measures to protect the personal data and traffic data provided to it or collected by it with due observance of the applicable obligations and exceptions under the relevant legislation.
We encrypt all transmission of information using secure socket layer technology (SSL). Your personal and traffic data can only be accessed by authorized employees of ours or our affiliates, subsidiaries or service providers who need to have access to this data in order to be able to fulfill their given duties.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied, or otherwise, that we will manage to prevent such access. If you feel that your privacy was treated in discordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at email@example.com.
Children are not eligible to use our Services and we ask that minors (under the age of 18) do not submit any personal information to us or use our Services. We do not knowingly solicit data from, or market to, persons under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without his or her consent, he or she should contact us at firstname.lastname@example.org. We will delete such information from our files.
8. LINKS TO THIRD PARTY SITES
9. POLICY UPDATES AND NOTIFICATIONS
If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at email@example.com.