We respect your privacy.
2. DATA & PERSONALLY IDENTIFIABLE INFORMATION
COMPANY may also combine your PII with other information to provide and improve our Website, products, Services, and content.
2.1 PII we collect
We collect PII you provide directly to us or which you generate when you open an account with us, use our Services or our Website. When we require certain PII from users it is because we are required by law to collect this data or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary.
You are free to choose whether to provide us with the types of PII requested, but we may not be able to serve you as effectively or offer you all of our Website functions and Services when you do choose not to share certain information with us.
2.2 Data collection when registering / using our Services
When registering on our Website(s), you may be asked to enter:
- Personal Identification Information: Full name, date of birth, age, gender, phone number, home address, and/or email.
- Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
We may also collect PII from third party partners and public sources as required or permitted by applicable law, such as public databases, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms which include:
- Financial information.
- Reputational information.
- Corporate/Business activities for corporate customers.
We use public databases and ID verification partners to verify your identity. Indeed, ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job position, public employment profile, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws.
In some cases, we may process additional data about you to ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contract with you and others.
2.3 Data collection when visiting our website
When visiting our website, we store every instance of access in a log file and therefore, the following Data are stored in this process:
- Computer or mobile device information
- Website from which our domain is accessed and Website usage information
- Operating system of your computer
- Country from which our Website is accessed
- Name of your internet provider
- Name and URL of the Data accessed
- Date and time of access
- IP address of the accessing computer
These Data are generally anonymized with no personal reference and only used to establish connection with the website, to ensure ongoing system security and stability and for statistical purposes. These Data are not associated or stored with PII.
IP address of the accessing computers will be analyzed only in the event of an attack on the network infrastructure or in case of suspicion of otherwise unauthorized or improper use of the website and for the sole purposes of defense or use as part of criminal proceedings for identification purposes and for criminal and/or civil proceedings against the user involved. IP address is also used to filter out geographical zones from accessing our Services.
3. HOW YOUR PII IS USED
Our primary purpose in collecting PII is to provide you with a secure, smooth, efficient, and customized experience. In general, we use PII to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes. We use your PII to create your account, to communicate with you about services you have purchased through the Website, to communicate offers for additional services and to complete sales transactions. We also use PII to enforce the terms of service under which the Website is provided to users and, if necessary, to prevent imminent harm to persons or property. From time to time, we may use your PII to: 1) comply with applicable laws and regulations; 2) improve the quality and performance of the Website; 3) to communicate with users; 4) provide customer service; 5) perform quality control in the operation of the Website; 6) assist with network and information security measures; 7) aide research and development related to the Website; 8) enhance the user experience of the Website; 9) assist with potential transactions involving the transfer of ownership of the Company or a business unit of the Company; and 10) engage with users for marketing purposes.
4. Cookies – Collection & Use of Data collected automatically
Cookies are small files that a site or its service provider transfers to your computer's hard drive through your web browser (if you have permitted) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Cookies are stored on the hard drive of your computer and do not necessarily transmit your PII to COMPANY.
Cookies are used to help COMPANY understand your preferences based on previous or current Website activity, which enables COMPANY to provide you with improved services.
Cookies are also used for security purposes and to compile aggregate Data about Website traffic and Website interaction so that better Website experiences and tools can be offered in the future.
COMPANY may also use trusted third-party service provider(s) that track this information on COMPANY’s behalf. Our service provider(s) will place cookies on the hard drive of your computer and will receive data that we select to educate us notably on: (i) how visitors navigate around our Website, (ii) what products are browsed, and (iii) general transaction information. Our service provider(s) analyses this data and provides us with aggregate reports. The data and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors' interests in our Website and how to better serve those interests. The data collected by our service provider(s) may be linked to and combined with data that we collect about you while you are using the Website. Our service provider(s) is/are contractually restricted from using information they receive from our Website other than to assist us.
You can choose to have your computer warn you (through your browser settings) each time a cookie is being sent, or you can choose to turn off all cookies. If you choose to turn cookies off, some of the features that make your Website experience more efficient may not function properly.
For the purposes of continuous optimization of the Website, COMPANY uses the web analysis service of “Google Analytics”. Google Analytics is a web analytics service offered by Google Inc., a company of the holding company Alphabet Inc., in the US, that tracks and reports website traffic. The data collected is processed in a non-personally-identifying form (IP Anonymization). Google Inc. discloses this information only to third parties to the extent required by law. Google uses the Data collected to track and monitor the use of the COMPANY’ s Website. This Data is shared with other Google services. Google may use the collected Data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/.
Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these websites, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp.
Cookies we use:
|Class||Purpose of the Cookies|
|Necessary Cookies||These cookies are necessary to maintain our services. They are usually only set in response to actions made by you, such as creating an account or saving a wish-list for later. You can set your browser to block or alert you about these cookies, but that can make some parts of the site not work. These cookies do not store any personally identifiable information.|
|Performance Cookies||These cookies allow us to count visits and traffic so we can collect insights like which pages are the most popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore, anonymous.|
|Functional Cookies||These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages.|
|Marketing Cookies||These cookies may be set through our site by our advertising partners to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but can identify your browser and internet device.|
5. THIRD PARTY ACCESS TO PII
We may disclose your PII to third parties and legal and regulatory authorities and transfer your PII as described below.
There are certain circumstances where we may transfer your PII to employees, contractors and to other parties.
We may also share your information with certain contractors or service providers. They may process your PII for us, for example, if we use a marketing agency. Other recipients/service providers include advertising agencies, IT specialists, database providers, backup and disaster recovery specialists, email providers or outsourced call centers. Our suppliers and service providers will be required to meet our standards on processing information and security. Third party service providers are required to agree to protect our PII using commercially reasonable data security measures which are similar to or better than our own. The information we provide them, including your information, will only be provided in connection with the performance of their function.
We may also share your information with certain other third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you. These include credit reference agencies, anti-fraud databases, screening agencies and other partners we do business with.
Your PII may be transferred to other third-party organizations in certain scenarios:
If we're discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
If we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you;
If we're required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
If we are defending a legal claim your information may be transferred as required in connection with defending such claim.
Your PII may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be PII.
Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide COMPANY Services or as required by law.
HOW PII IS SHARED WITH THIRD-PARTY SITES AND SERVICES
Information collected by third parties, which may include such things as contact details or location data, is governed by their privacy practices. We encourage you to learn about the privacy policies of those third parties.
If you authorize one or more third-party applications to access your COMPANY Account, then information you have provided to COMPANY may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using COMPANY Services.
6. TRANSFER OF DATA
The Website is hosted in the US. We do not store or transfer your PII outside the US.
7. SECURITY OF DATA
We take commercially reasonable effort on technical and organizational security measures to protect your PII from being manipulated, lost or accessed by unauthorized third parties.
Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website as safe as possible.
Your PII is contained behind secured networks and is only accessible by a limited number of individuals who have special access rights to such systems and are required to keep the information confidential.
We employ data security tools to protect your PII including encryption and authentication tools. All orders made through the Website are certified Level 1 PCI DSS compliant through our vendor, Shopify. We use our vendor HubSpot cooperatively with Shopify to provide additional security for our membership services. Even with these tools in place and properly functioning, we cannot guarantee the unconditional security of any PII. By using the Website, you acknowledge and agree that we make no such guarantee, and that you use the Website at your own risk.
We would like to draw your attention on the fact that we normally never ask for financial or payment information, such as your credit card number, passcode, account number or pin number, in an e-mail, text or any other communication that we send to you. Please always check that any website on which you are asked for financial or payment information in relation to our reservations or services is operated by COMPANY. The risk of impersonating hackers exists and should be taken into account when using our Website and/or Services.
Since we cannot 100% guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please accept that you play a vital role in protecting your own PII. When registering with us, it is important to choose an appropriate password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.
8. RETENTION OF PII
COMPANY will retain and use your PII to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Therefore, and In accordance with our record keeping obligations, we will retain Account and other PII for at least five years (and some up to ten years, as required by applicable law) after an Account is closed.
8.2. Data Collected Automatically
COMPANY will also retain Data Collected Automatically either generated by the use of the website or from the website infrastructure itself (for example, the duration of a page visit)) for internal analysis purposes.
This Data is generally retained for a shorter period of time, except when this Data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this Data for longer time periods.
Hence, this kind of Data collected via technical means such as cookies, webpage counters and other analytics tools is normally kept for a period of up to one year from expiry of the cookie.
9. DISCLOSURES DUE TO LEGAL COMPLIANCE
COMPANY complies with all applicable privacy laws and regulations.
COMPANY may be compelled to surrender personal user or customer information to legal authorities without express user consent if presented with a court order or similar legal or administrative order, or as required or permitted by the laws, rules, and regulations of any nation, state, or other applicable jurisdiction.
Also, in the event of a violation of the terms and conditions of use of the Website or a violation of any restrictions on use of materials provided in or through the Website, we may disclose personal user information to our affected business partners or legal authorities.
If you believe that we have improperly handled your PII, we encourage you to contact us first at email@example.com so that we can try to resolve the issue informally.
11. CHILDREN'S PII
We do not knowingly request to collect PII from any person under the age of 18.
If a user submitting PII is suspected of being younger than 18 years of age, COMPANY will require the user to close his or her account.
We will also take all necessary steps to delete his or her Data as soon as possible.
12. LINKS TO OTHER WEBSITES
COMPANY’s website may contain links to other sites that are not operated by COMPANY. If you click on a third-party link, you will be directed to that third party's site.
COMPANY has no control over and assumes no responsibility for the content, privacy policies or practices of any third-party sites or services.
14. CONTACT US