PRIVACY POLICY OF THE MONEYMAILME LTD.

This Privacy Policy governs your use of the products, services, content, features, technologies or functions offered by Moneymailme Ltd. and all related sites, applications, and services (collectively the “Services”) (including, without limitation, when you provide any information in relation to your use of the Services). 

You accept and consent to this Privacy Policy when you sign up for, access, or use the Services. By accepting and consenting to this Privacy Policy, you expressly consent to our use and disclosure of your Personal Data and direct us to do so in the manner described in this Privacy Policy.

Moneymailme is an innovative chatting app that combines the social interaction with the joy of sending and receiving available e-money from your mobile phone in what has been termed “social money”, fast and secure. From sending money back to your friend who paid earlier for your coffee at the University, to contributing with your office colleagues to buying a gift for your boss, Moneymailme facilitates micro-payments, file sharing and chatting at the same time, allowing you to make a really enjoyable social experience out of payments. The functions of the Moneymailme application are described in more detail under the Terms of Service.

AGE RESTRICTION

Moneymailme as a Social App is not suitable for children under the age of 16. If they would choose to use Moneymailme for any reason, they must first seek parental/guardian consent to this Privacy Policy (both for themselves and on your behalf). We do not intentionally collect Personal Data from any children under the age of 16 without such consent. Please contact our team, if you have reasons to believe that we have personal data originating from children under the age of 16. Payment Services are not suitable for people under the age of 18, or higher, if your jurisdiction requires a higher age in order to be considered an adult.

WHAT PERSONAL DATA WE COLLECT FROM YOU AND HOW?

When using the Services and to the extent you wish to take full benefit of the functionalities, you shall be required to provide certain personal data, such as those listed below, disclosed to Moneymailme during certain events when using our Services, processed for the reasons and throughout the duration mentioned therein next to each.

CATEGORY OF DATA

DATA

Received from

Form used

Application

Time of receipt

Reason

Legal basis

Duration

PERSONAL

First Name

User

Form

Mobile

Registration

(mandatory) No e-wallet may be created with a financial institution, unless disclosing these details.

Email is required to validate that a valid user has access to the application and to send notifications regarding the application to that user.

Phone number is required because the validation of the account creation is done via the phone supposedly in the hands of the user.

Consent / required for the execution of the contract

Until the deletion of

the account,

or at the elapse of 3 years if the

account is no longer accessed.

Last Name

User

Form

Mobile

Registration

Email

User

Form

Mobile

Registration

Phone Number

User

Form

Mobile

Registration

Date of Birth

User

Form

Mobile

Registration

Country of the Nationality

User

Form

Mobile

Registration

LOCATION

Country of the Residence

User

Form

Mobile

when user decides, in My Account

Optional information, however, no withdrawals of e-money can be made, without the submission of this information required by payment processors. Once an address was created, it can never be removed.

Consent

until user decides to delete

account or at the

elapse of 3

years if the account

is no

longer accessed.

Address (line)

User

Form

Mobile

when user decides, in My Account

City of Address

User

Form

Mobile

when user decides, in My Account

Region of Address

User

Form

Mobile

when user decides, in My Account

Country of Address

User

Form

Mobile

when user decides, in My Account

Zip Code of Address

User

Form

Mobile

when user decides, in My Account

PHONE-LOCATION

Latitude and Longitude

User

Alert

Mobile

when user decides to share a location in Chats screen

a location sharing is done by manually providing the latitude and longitude of that location in the chat service to another user.

Consent

as long as the

provider

decides

PROFILE-GIVEN

Occupation

User

Form

Mobile

when user decides, in My Account

Optional information, however, no withdrawals of e-money can be made, without this information required by payment processors. Once an address was created, it can never be removed.

Consent

until user decides to delete

account

Income Range

User

Form

Mobile

when user decides, in My Account

Screen Status

User

Form

Mobile

when user decides, in My Account

(optional) the user is allowed to display a status of his/her choice; if the user does not input one, the system assigns a default status

 

Profile Photo

User

Form

Mobile

when user decides, in My Account

(optional) the user is allowed to display a photo of his/her choice; if the user does not upload one, the systems assigns a default photo. Once set, cannot be removed.

Consent

SECURITY

Password

User

Form

Mobile

Registration

(mandatory) as security measure, without a password no user is allowed to create an account

Consent

until user decides to delete

account

Password history

User

Form

Mobile
User Web Application

Settings
Forgot Password

due to a PCI DSS requirement, a user needs to change the password every 90 days

Security Code

Application
User

Internal generation tool
Form

Server
Mobile

Registration
when user decides to change it (when executing any transaction)

the user must validate any financial transaction performed in the application with a security code uniquely assigned to him/her

KYC

Document Type

User

Form

Mobile

when User decides, in My Account

(optional) without these, user can have a maximum of EUR 2,500 worth of cash-ins (deposits or transfers from other users) and EUR 1,000 worth of cash-outs (withdrawals or transfers to other users)

Consent

until user decides to delete

account

Document Image

User

Form

Mobile

when User decides, in My Account

Consent

PROFILE-DETERMINED

Account creation timestamp

Application

Software

Mobile

Registration

reports need to be generated for number of users creating during a period, to be able to know if Marketing campaigns work

Consent

until user decides to delete

account

Timestamp of last activity

Application

Software

Mobile

Any action performed by the user

reports need to be generated for inactive users, or to determine if the application does not support a certain OS version (e.g. Android 4.4) depending on the inactivity;
to determine what to display in the user status (Online, last seen on …)

 

IP of last activity

Application

Software

Mobile

Any action performed by the user

This is needed to determine if the user is involved in fraud from the point of view of: is the user has used many alias accounts

Wrong login attempts from an IP

Application

Software

Mobile

Login

This is a functionality to determine if a User needs to be logged out after 6 wrong attempts from the same IP and in order to forbid the login from the same address for a period of 30 minutes

Phone language (RO or EN)

Application

Software

Mobile

When user sets/changes the phone language (and opens the M3 app)

messages in the application must be displayed in the language of the User

Operating System Type

Application

Software

Mobile

Registration and any time the user changes the phone

the OS of the phone users’ different libraries depending if it is Android or iOS (example: push notifications)

Phone Brand and Model

Application

Software

Mobile

Registration and any time the user changes the phone

in case of bugs or incorrect behavior, it is needed to isolate the phone brand and model to know if the incorrect behavior occurs generally or just for a certain phone

PROMOTIONS

Use of a promo code

User

Form

Mobile

when user decides, in Promo Code

a user cannot use a promo code more than once

Consent

until user decides to delete account (however, the fact

that a promotion

code was used will

not be deleted)

FINANCIAL-IN-APP

Wallet currency

User

Form

Mobile

Registration

(mandatory) the user has to choose a currency for the wallet which is being created for him/her in the application.

Consent

for 6 years

Wallet balance

Provider

API

Server

any successful financial transaction processing

(mandatory) the User needs to know how many funds he/she has in the wallet

Transactions (deposit, withdrawals, in-app transfers) – amount, currency, type, direction, creation timestamp, from, to

User

Form

Mobile

any financial transaction initiation

the application deals with funds
the user needs to know what transactions he/she executed
the provider and the application need to track financial activity of users

DEPOSIT-CARD

Card Type (VISA/MASTERCARD)

User

Form

Mobile

Deposit

(conditional) the user needs to specify a card in order to deposit funds on the application wallet. However, the card exact details are managed directly by the service provider. Moneymailme only retains what is needed to be displayed in the app.

Consent

until user decides to delete

account

Expiration Date

User

Form

Mobile

Deposit

Card Number first 6 last 4

User

Form

Mobile

Deposit

Expiration Date

User

Form

Mobile

Deposit

ID of the Card at provider

       

DEPOSIT-CARD-SENSITIVE

Card Number full

User

Form

Mobile

Deposit

Consent

as long as the

provider decides

Card CVV

User

Form

Mobile

Deposit

BANK-ACCOUNT

Owner Name

User

Form

Mobile

Withdrawals

(conditional) the user needs to specify a card in order to withdraw funds from the application wallet.

Consent

until user decides to delete

account

Bank Account Data

User

Form

Mobile

Withdrawals

M3-BRANDED-CARD

Emboss Name

Provider

API

Server

Cards

the app needs to have the minimum amount of information about a Moneymailme branded card for which a user has applied using the application

Consent

for 6 years

Card Type (VIRTUAL/PHYSICAL)

Provider

API

Server

Cards

Card Number last 4

Provider

API

Server

Cards

ID of the Card at provider

Provider

API

Server

Cards

Card currencies

Provider

API

Server

Cards

 

Card transactions – amount, currency, type, direction, creation timestamp

Provider

API

Server

Cards

the app deals with the transfer of funds, while the user, the payment services provider and the app need to track financial activity of users in order to execute these

M3-BRANDED-CARD-SENSITIVE

Card Number full

Provider

API

Server

Cards

(only for virtual cards) virtual card information is available only inside the mobile application

Consent

as long as the

provider decides

Card CVV

Provider

API

Server

Cards

CHAT-MESSAGES

Text messages text

User

Form

Mobile

Chats

to facilitate delivery of communication to another user

Consent

and until user

decides to

delete messages

or the account

 

Chat notification – sender mobile phone, date when sent, chat text or content (shared item)

Application

Software

Server

Chats

to assure a proper functioning of the application

Execution of the Terms of Service

 

User notification sent by customer support – title, content, priority

Application

Software

Admin Web Application

whenever Customer Support decides to inform users; this will not be used to send Marketing messages

Delete chats notification – an indicator to delete all chat messages from the mobile phone

Application

Software

Server

when the user logs to his/her Account Web Application and chooses to delete all messages from the mobile application

Message receipt notification – an indicator to notify a user sending a chat message that the message was delivered and seen

Application

Software

Server

Chats

Balance update notification – new wallet balance value

Application

Software

Server

any transaction which impacts a wallet balance

LOGS

Server-side logs (various personal data)

Application

Software

Mobile
Server

any action

technical customer support needs to be able to investigate issues by looking at logs in order to find the cause of a problem and the appropriate solution

Consent

for 18 months

Mobile logs (no personal data)

Application

Software

Mobile

any action

mobile developers need to be able to investigate issues by looking at logs in order to find the cause of a problem and the appropriate solution

Consent

as longs as the

mobile developer

decides

EMAIL-CONTENT

Transaction data

Application

Software

Server

any action where automatic emails are sent

the application needs to inform the user about any remarkable action that he/she did in the application, for security reasons

Consent / required for the execution of the contract

the email is sent from the

application, directly during

processing, using an emailing

provider

We are collecting this Personal Data which is mandatory and it is required for us to be able to deliver the Services to their full extent. To the extent you do not wish for certain Personal Data to be disclosed, you will need to refrain from using the respective part of the Services, which requires the respective Personal Data to be processed by us and our respective service provider.

When you are registering, subscribing or using our Services, you consent to the use of your personal data in line with this policy. We may also receive information about you from our Group and from third parties, with whom we have a business relationship and who are supporting us to deliver the Services.

For the sake of clarity, Group shall mean the following entities:  MoneyMailMe Ltd and Modex Ltd and Ingenium Media S.R.L. and other companies which are affiliated parties to the foregoing.

WHERE DO WE STORE PERSONAL DATA, LOCATION

Except for the transfer of personal data to the third party service providers herein, the personal data that we collect from you will be transferred to, stored, or processed in Romania.

Our marketing and technical support teams that ensure the supply of the Services to the Users are located in offices from Bucharest, Romania and have access to your data in order to provide the Service (for example, to fix technical issues).

HOW MAY THIS INFORMATION BE USED?

Whenever you give us your Personal Data via the Moneymailme application, we will use it in accordance with applicable privacy laws of your jurisdiction and for the purposes set out in this policy.

WHEN YOU USE OUR SERVICES:

If you use any of our Services, set up, look at or change your account details or contact our Support Team, we will record your Personal Data that you transmit to us. Your information will be used in the first place to provide the Services you have asked for and to provide you with a personalized user experience.

Saved payment card details will only be shared with our payment processing partner and not with any other third parties and will only be used to process your order, using our payment partner’s systems.

We may also use your Personal Data to send you marketing updates, as detailed in the next section and to the extent you have manifested your positive consent.

TESTIMONIALS:

If you give us feedback, we may use it to improve our Services and we may publish it online or offline to promote our business and our services. You will be made aware and we will ask for your consent before we publish it.

SOCIAL NETWORKS:

If you follow us or interact with us on any of our pages on third party social media platforms, such as Instagram, Facebook, Twitter, Telegram, the information you provide there will be subject to the third party’s privacy policy, as well as this privacy policy.

Please note that we do store the messages that you deliver to us via social networks according to each one’s privacy policy; we might need to use them for internal reasons such as customer satisfaction or dealing with possible issues or complaints that are transmitted to us via social media, but, except for complaints, we do not link the identity details of the respective person with the message of the same.

CUSTOMER SURVEYS:

From time to time, we may ask you for your opinion on our services and the products you have used our services.

WHO WE WILL SHARE YOUR PERSONAL DATA WITH

The Data Controller of the data collected and processed through the Site is moneymailme Ltd.

We employ third-party service providers which provide important functions to us that allow us to be an easier, faster, and safer way to deliver our Services. We need to disclose user data to them from time to time so that the Services can actually be performed.

We have listed in this Privacy Policy the third-party service providers and business partners to whom we may disclose your data, together with the purpose of disclosure and type of information disclosed.

Provider

Role

Categories of personal data disclosed

Comments

Reason for data transfer

Description of reason

Jurisdiction

Duration

Mango Pay

processor

PERSONAL

 

electronic money service provider (holds EMI license) and KYC provider

due to the fact that the provider is an institution having an EMI license, they themselves require these data in order to create electronic wallets for users (and allow wallet-to-wallet transactions, deposits into wallets and withdrawals from wallets) and in order to increase the limits of transacting inside the app:
– without PERSONAL, an electronic wallet can never be created (a.k.a FINANCIAL-IN-APP)
– without LOCATION, PROFILE-GIVEN. Occupation and PROFILE-GIVEN. Range, withdrawals can never be created.
– without KYC, a user can have 2500 EUR worth of cash-ins (deposits or transfers from other users) and 1000 EUR worth of cash-outs (withdrawals or transfers to other users)
– DEPOSIT-CARD data is required in order to deposit funds inside the app; sensitive card data is never retained by Moneymailme application, it is processed in a secure way by the provider.
– BANK-ACCOUNT data is required in order to withdraw funds from the application
the provider and the Customer Support department collaborate together in order to determine the fraud, as Moneymailme Ltd. is liable for any fraud (where the prejudice cannot be recovered)

Luxembourg
For sub processors – other E.U. countries

5 years after the last use of the user account

 

LOCATION

 
 

PROFILE-GIVEN

only Occupation and Income Range

 

KYC

 
 

FINANCIAL-IN-APP

these data are actually generated by the provider

 

DEPOSIT-CARD

 
 

DEPOSIT-CARD-SENSITIVE

 
 

BANK-ACCOUNT

 
 

PROVIDER

Prevention or detection of fraud

Prepaid Financial Services

processor

PERSONAL

 

MasterCard multi-currency cards provider

the provider issues Moneymailme branded cards (multi-currency with EUR, USD and GBP) and it requires user data in order to issue them only for eligible users:
– PERSONAL data is necessary in order to know the person name, date of birth and contact details (email and phone).
– LOCATION is necessary in order to identify the person and send the card to the respective address.
– BANK-ACCOUNT is necessary in order to cash out the card funds when a user wishes to close a card.
FYI: users must not be blocked by the application, must reside (nationality or proven address) in SEPA area, KYC must already be performed, nationality and address are proved with appropriate documents.

UK

Other providers involved in the processing:
M2 – in USA (card processor)
Gemalto – in UK (

6 years from the end of the business relationship

 

LOCATION

 
 

BANK-ACCOUNT

 

Amazon Web Services

processor

PROFILE-DETERMINED

 

cloud servers provider

holds application entire architecture, including the database
offers S3 Bucket service, where media files (like document links and user profile photos) are kept

US

as long as the application management decides, according to what is mentioned in column N from “Personal Data Categories” tab

 

PERSONAL

 
 

LOCATION

 
 

PROFILE-GIVEN

 
 

SECURITY

 
 

KYC

 
 

PROFILE-DETERMINED

 
 

PROMOTIONS

 
 

FINANCIAL-IN-APP

 
 

DEPOSIT-CARD

 
 

BANK-ACCOUNT

 
 

M3-BRANDED-CARD

 
 

CHAT-MESSAGES

 
 

LOGS

only Server-side logs

 

PROVIDER

only data received from Identity Mind

Mandrill (Mailchimp)

processor

PERSONAL

only First Name, Last Name and Email

emailing services

used to send any application automatic email from an address owned by an application domain to a user or to an address owned by an application domain

US

30 days – for delivered message
90 days – for bounced message data

 

EMAIL-CONTENT

 

Nexmo

processor

PERSONAL

only mobile phone number

SMS services

used to send an SMS to the mobile number provided by the user during registration, in order to validate that the given mobile number is valid and is in the hands of the person doing the registration

US, EU, Singapore, UK, Netherlands, Germany

13 months – call details records
30 days – technical logs

Google Analytics

processor

BEHAVIOR-PURPOSE

 

product behavior analytics

application use analysis (what functions are visited, how much time does a user use the application, how much time does a user spend in a screen, how many users having a certain OS system use the application, etc.)

not communicated by the provider

as long as the controller establishes unlimited

Crashlytics

processor

LOGS

only Mobile logs (phone model, OS version, stack trace)

mobile application crash reporting

mobile developers need to be able to investigate issues by looking at logs in order to find the cause of a problem and the appropriate solution

not communicated by the provider

90 days

Google Places

processor

PHONE-LOCATION

 

location sharing

when a user shares his location voluntarily. This information is generated by your phone

not communicated by the provider

not communicated by the provider

Google Cloud Messaging

processor

NOTIFICATIONS

 

mobile notifications service (for Android OS)

standard mobile function which needs to be supported by any mobile application

not communicated by the provider

not communicated by the provider

Apple Push Notification Service

processor

NOTIFICATIONS

 

mobile notifications service (for iOS OS)

standard mobile function which needs to be supported by any mobile application

not communicated by the provider

not communicated by the provider

Currency Layer

processor

N/A

the server component retrieves exchange rates from provider, does not provide any data to the provider

currency rates provider

N/A

N/A

N/A

Tokbox

processor

N/A

the mobile application creates a session at the provider and adds users to the session (users who want to join the call) by a random unique ID; the session is the video call or the audio call; the provider does not receive any data of any sort

audio and video call provider

N/A

N/A

N/A

Up Trends

processor

N/A

the provider performs periodic calls to the server component and this component returns to the provider a status for each of the various components it wants monitored, under the following format: “R001”:1. “R001” – stands for a rule code, 1 – stands for the status (failed, critical or OK); the provider does not receive any user data in any sort

monitor downtimes and informs a designated group of people about the crash

N/A

N/A

N/A

By accepting this Privacy Policy and maintaining an account with us, you expressly consent to the transfer of your data to those third parties for the purposes listed in the table above.

We reserve the right to update the list of such partners. We acknowledge that we will only start transferring any data to any of the new entities or for the new purposes or data types indicated in each update after 30 days from the date when that list is made public through an amendment to this Privacy Policy.

You should review the list regularly in order to become acquainted with the new list of recipient entities. If you do not object to the new data disclosure, within 30 days after the publication of the updated list of third parties, you are deemed to have accepted the changes to the list and to this Privacy Policy. If you do not agree with the changes, you may close your account and stop using our Services or you may continue to use the Services, but not to their full extent.

In order to provide the Services, certain of the information we collect may be required to be transferred to other group entities or other entities, including those referred to in as part of the Group in their capacity as payment providers, payment processors or account holders (or similar capacities). You acknowledge that according to their local legislation, such entities may be subject to laws, regulations, inquiries, investigations, or orders which may require the disclosure of information to the relevant authorities of the relevant country. Your use of the Services constitutes your consent to the transfer of such information to provide you the Services.

For any further information on the data processors and to see the complete list of the designated data processors, please contact moneymailme Ltd at the following email address: support@moneymail.me.

We will share your information with other companies in our Group, who may use it for their own business purposes, as set out in their privacy policy. These purposes may include financial reporting and analysis, strategic planning, the development of customer segmentation and metrics to provide a consistent view of our customer base, research and analytics, to help us source the right Services in future and make better services recommendations, more effective targeting of our marketing campaigns, the development of new products and collaboration opportunities, fraud prevention, anti-money laundering, enabling service providers under contract with us to support our business operations, such as fraud prevention, marketing, customer service and technology services.

From time to time, we receive requests for information from government departments, the police and other enforcement agencies. If this happens, and there is a proper legal basis for providing your Personal Data, we will provide it to the public organisation asking for it.

In case moneymailme Ltd would merge with or be acquired/absorbed by another company, then you herewith express your consent to the successor company having access to the information collected and processed by moneymailme Ltd, including customer and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.

WHERE WE PROCESS YOUR PERSONAL DATA AND FOR HOW LONG

The personal data we collect or generate (process) in the context of our application are stored in the country of origin of the third party online data processor, acting as our storage services provider, as listed above. When we use your information as described in this policy, this may involve sending your information outside the European Economic Area (EEA).

When we do this, we make sure that appropriate steps are taken to protect your Personal Data and your rights. By providing us with your Personal Data, you agree that we may transfer, store and process your information outside the EEA. Governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.

The information that is required to be given by you is retained/stored for as long as the laws in force provide for each type of information. When exporting the data and information that you provide to us, we will use our own export solution. When doing so, you are entitled to (i) obtain a copy of the data, (ii) the source of the data (if not the data subject him/ herself) and (iii) whether obtained from a public source, and (iv) more information on wholly automated processing.

You are entitled at any time to withdraw your consent on the storage and processing of your personal data and to lodge a complaint to the Supervisory Authority of your home country. If and once the consent to the storage and processing of your personal data is given, this may impact on the provision of the services, leading to likewise suspension or interruption of the Services that we provide to you, as most details that we store and process are required for the Service to be provided to you or for legitimate bookkeeping or auditing purposes or for other mandatory requirements which would under relevant jurisdictions oblige us to keep such data for further governmental or state inquiries, for a certain period of time.

DATA SUBJECT RIGHTS. YOUR RIGHTS

Under the General Data Protection Regulation (GDPR) (EU) 2016/679, Users have the following rights and we are obliged to ensure that they are exercisable by Users to their full extent.

These rights may be summarized and described, as follows:

  1. Accessing your Personal Data & Correction of the Personal Data

Upon your explicit request, we shall provide you with information about whether we hold any of your personal data. You also have the right to access such personal data and to know how we use it and who we share it with. You also have the right to correct the personal data by logging into your account at any time.

If you believe we hold any other personal data that is not available to correct in your account or you wish to correct any personal data which is unavailable in your account, please send us an email at support@moneymail.me.

With respect to correction requests, where we agree that the personal data is incorrect, we will communicate the corrected data to the party to whom we have disclosed it, such that rectification can be ensured to whoever holds this data as our processor.

  1. Deletion of your Personal Data

You can either delete your account, or remove certain Personal data, by simply logging into your account and following the account deletion instructions here. If there is any other Personal data you believe we process that you would like us to erase and you cannot or will not do it yourself from your account, please send us an email at support@moneymail.me.

You may request that we erase the Personal data we hold about you in the following circumstances:

You can either delete your account, or remove certain Personal data, by simply logging into your account and following the account deletion instructions 

  • you believe that it is no longer necessary for us to have your Personal data;
  • we obtained your consent to process the Personal data and you withdrew that consent (and we have no other grounds for processing the Personal data);
  • you believe we are unlawfully processing your Personal data;
  • you are or were under the age of 13 when we collected the Personal data and we can verify your age.

Also note that you may exercise your right to restrict our processing your Personal data (as described below) whilst we consider a request to erase your data.

Please note, however, that we may retain the Personal data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims, freedom of expression or some other legal obligation) but we will let you know if that is the case.

Where you have requested that we erase your Personal data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Personal data or providing links to the Personal data to delete that too.

  1. Restriction of Processing to Storage Only

You have a right to require us to stop processing the Personal data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Personal data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defense of legal claims or for another’s protection).

Where we agree to stop processing the Personal data, we will tell any third party to whom we have disclosed the relevant Personal data so that they can stop processing it too.

You may request we stop processing and just store the Personal data we hold about you where:

  • you believe the Personal data is not accurate (for the period it takes for us to verify whether it is accurate);
  • we wish to erase the Personal data as the processing we are doing is unlawful (but you want us to retain the Personal data and just store it instead);
  • we wish to erase the Personal data as it is no longer necessary for our purposes (but you require it to be stored for the establishment, exercise or defence of legal claims).
  1. Data Portability

You have the right to receive a copy of certain Personal data we collect from you. This comprises any Personal Data we process on the basis of your consent (e.g., chat communications, voluntarily-provided profile data) or pursuant to our contract with you (e.g., profile data). You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that Personal Data to another party.

If you wish for us to transfer the Personal data to a third party, please ensure you detail that party.

  1. Objection

You may object to our use of your Personal data if we use your information on the basis of our legitimate interests (such as when we use your Personal Data for your account security, such as to prevent malicious log-ins or aliases). If you object to such processing, please state your reasons and communicate these to us to the email support@moneymail.me.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us sending a separate email to this effect.

Should we receive any such notice on the exercise of your rights, we must take action within 1 month of having received your request.

MARKETING OPT-IN AND OPT-OUT PROVISION

You have the right to ask us not to use your Personal Data for marketing. In the unlikely situation you receive direct marketing from us, we will tell you how to unsubscribe. To opt out of direct marketing emails, please contact our Support team by email at support@moneymail.me.

If you communicate to us that you do not want to receive direct marketing, we will exclude your contact details of our subscription list and you will no longer be provided with the respective information on our Services, but you will still be able to access such services.

HOW YOU CAN ACCESS AND UPDATE YOUR PERSONAL DATA

You have the right to see the information we hold about you, with some exceptions which are described in the privacy laws. If you would like a copy of your Personal Data, please contact our team at support@moneymail.me.

You have the right to review and update your personal details. If for any reason you are concerned that the Personal Data we hold is not correct, please log into the application review and change in the MyAccount section. You can change or delete saved credit/debit card details any time. You will also be able to delete saved credit/debit card details by adding or editing a shipping/billing address.

Our Live Chat conversations are stored forever. To receive a copy of your chat conversation simply request this on Live Chat or contact our Support team by emailing us at support@moneymail.me.

SAFEGUARDING YOUR PERSONAL DATA

We will take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided to us. We have put in place technology and security policies which are designed to protect the Personal Data we hold about you. We also follow the security procedures required by applicable privacy laws.

This covers storing, using and releasing any information you have provided and, as well as measures designed to prevent unauthorised access or use. When you access your account information, we use a Secure Socket Layer (SSL) encryption which encrypts your information before it is sent to us to protect it from unauthorised use.

In limited situations where quick actions need to be taken we might need to transmit your data through internal communication tools, to a limited number of people in our support team, to be able to provide you with rapid answers and technical fixes.

Also, online payments that we provide in our application are managed by a third-party services provider. The third-party services provider functions on the basis of a wallet systems, accepting a limited number of currencies. We do not hold any information regarding your credit card information, while such information is stored only with the third-party services provider. For the identity of such third-party services provider, please review the above table.

HOW CAN MAKE WE CHANGES TO THIS POLICY

We may update this privacy policy from time to time so you may want to check it each time you give us Personal Data or you use our application. When we update this policy, the changes will not be retroactive. We state that if you do not accept changes we make, you can terminate this policy and may stop using the part of the Services, which cannot otherwise function, except with your consent.

WHERE AND HOW TO ASK QUESTIONS OR CONTACT US ABOUT THIS POLICY

If you require further information about our privacy policy, please contact our Support team. We welcome your questions, comments and requests regarding this privacy policy. If you require more information, please contact our Support team at support@moneymail.me.