May 24, 2018
This policy together with the General Terms of Service apply to your use of:
a) The web-sites of SnapSwap International S.A.: www.snapswap.eu and www.gloneta.com (the "Sites")
c) The Gloneta Money Messenger App ("Gloneta App") once you have downloaded a copy of the App onto your mobile telephone or handheld device ("Device"); and
d) any of the services accessible through the App or the Site (the "Services").
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.
SnapSwap International S.A. is the data controller responsible for your personal data.
Data Protection Officer
We have appointed a data protection officer ("DPO"). Our DPO has a number of important responsibilities including:
- monitoring compliance with the GDPR and other data protection laws;
- raising awareness of data protection issues, training SnapSwap International S.A. staff and conducting internal audits; and
- cooperating with supervisory authorities on our behalf.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us or our DPO via support channels (email@example.com or firstname.lastname@example.org).
You have the right to make a complaint at any time to The the EU’s independent data protection authority (“EDPS”) www.edps.europa.eu. We would, however, appreciate the chance to deal with your concerns before you approach the EDPS so please contact us in the first instance.
We will always keep your data safe and private, never sell your data, allow you to manage and review your marketing choices at any time.
When you access our Sites or content or use our applications or SnapSwap services, we may place small data files called cookies or pixel tags on your computer or other device. We use these technologies to:
- Recognize you as a customer
- Customize services, content, and advertising
- Measure promotional effectiveness
- Collect information about your computer or other access device to mitigate risk, help prevent fraud and promote trust and safety
We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.
We also use Local Shared Objects, commonly referred to as "Flash cookies", to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud and to support our sites and services.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our website. The help section of most browsers or browser add-ons provides instructions on blocking, deleting or disabling cookies.
Information we collect about you
We will collect and process the following data about you:
- Information you give us "Submitted Information": This is information you give us about you by filling in forms on the Gloneta App and/or the Sites, or by corresponding with us by email. It includes information you provide when you register to use the Gloneta App, download or register the Gloneta App, subscribe to any of our services, enter into any transaction on the Gloneta App or the Sites, enter a promotion or survey and when you report a problem with the Gloneta App, the Services, or the Sites. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, the Device's phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, driving licence and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.
- Information we collect about you and your device. Each time you visit the App or our Sites we will automatically collect the following information:
- Technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting "Device Information";
- Information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information;
- Transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used;
- Information stored on your Device, including if you allow SnapSwap access contact information from your address book, login information, photos, videos or other digital content, check ins (Content Information). The Gloneta App will periodically recollect this information in order to stay up-to-date;
- Details of your use of our App or your visits to our Sites including transaction details relating to your use of our services, including who you have sent money or electronic money to, foreign exchange transactions you have entered into, the time, date and location of the place the transaction was entered into.
- Location Information. We may use your IP address to determine your location – this may be used when the App is running in the foreground and the background of your Device. This is used to prevent fraud, for instance if your mobile phone is saying that you are based in Luxembourg but your transactions always take place from the US, we may perform manual AML checks to investigate these cases.
- Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, fraud prevention agencies, customer service providers and developers. Information we may collect about you from such parties can include information which helps us to verify your identity or information relating to your payment transactions. Please see the 'Disclosure of your Information' section for more information.
Uses made for the information
Below is a summary of data that we make use as part of our Services.
We use information held about you in the following ways:
- Submitted Information: We will use this information:
- to carry out our obligations arising from any transactions you enter into with us, for example Top Ups, Money transfers, Withdrawals, and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services;
- to notify you about changes to our service;
- to make you aware if any of your contacts who are Gloneta users have utilised Gloneta Money Messenger;
- to ensure that content from our sites is presented in the most effective manner for you and for your computer.
- Device Information: We will use this information:
- to administer our Sites and the Gloneta App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Sites and the Gloneta App to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep our Sites and the App safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Sites and the App about goods or services that may interest you or them;
- to verify your identity, protect against fraud, comply with anti-financial crime laws and to confirm your eligibility to use our products and services; and
- to comply with our regulatory obligations.
- Third Party Information: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information:
- to process applications for products and services available through us including making decisions about whether to agree to approve any applications;
Disclosure of your information
Data processing partners
We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws.
We send personal data to the following sets of data processors in order to perform the Services:
- Fraud prevention agencies
- This is in order to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services;
- Cloud storage providers
- This is in order to safely and securely store your data with SnapSwap;
- Banking and financial services partners
- Financial services providers that help us provide the Services including banking partners, banking intermediaries and international payments services providers;
- If SnapSwap or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- In order to:
- enforce or apply the General Terms of Service and/or any other agreements between you and us or to investigate potential breaches; or
- protect the rights, property or safety of SnapSwap, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Third party service partners
From time-to-time, we may partner with certain third parties in order to offer you co-branded services or promotional offers. In order to provide these services to you and to allow us and any associated third party to optimise their/our offering to you, we will share some of your personal data with such third parties. We will obtain your express opt-in consent before we share your personal data with any third party company.
You can withdraw your consent at any time after giving your explicit opt-in consent by contacting support via email.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be securely encrypted and stored. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App and/or our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App or our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retaining your information
SnapSwap is obligated under the The European Union Fourth Anti-Money Laundering Directive to retain personal data about you and your transactions for a period of five years. Also, as an authorised e-money institution, we are under further regulatory obligations to retain your data for a certain amount of time. We therefore use this retention requirement as a benchmark for all personal data that we receive from you. In order to not hold your information for longer than is strictly necessary we will not hold any of your personal data for more than 6 years after the termination of our business relationship.
Marketing and Communications
We want to make it crystal clear how we use your data for marketing purposes and how you can unsubscribe from receiving any marketing communications from us whenever you want. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your personal data (such as your Submitted Information or Location Information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have signed up to and/or utilise the Services and, in each case, you have not declined receiving marketing notifications.
We will obtain your opinion before we share your personal data with any third party company for marketing or promotional purposes.
We may use your Personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by notifying us via email.
Your legal rights
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"). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team email.
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. If you require this, then please reach out to our support team via email.
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. As an e-money institution, SnapSwap is under certain obligations to retain certain data for a minimum of 6 years (see above). Please note that these retention requirements supersede any right to erasure requests under applicable data protection laws.
Object to processing of your personal data. This is in situations 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. As an e-money institution, SnapSwap is under certain obligations to process and retain certain data for compliance purposes. Please note that these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data then we may not be able to provide the Services and it is likely we will have to terminate your account.
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. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the Services). In this case, we may have to cancel your use of the Services but we will notify you if this is the case at the time.
Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. 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. If you require this then please reach out to our support team via email.
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 the Services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you fail to provide personal dataWhere 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 (including the Services). In this case, we may have to cancel your use of the Services but we will notify you if this is the case at the time.