Last Material Update: 22 January 2021
If you are not a California resident, please check our Global Privacy Notice.
- Important informationa and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Personal Data retention
- Your legal rights
Data Protection Officer, Complaints and Contact details
Email: [email protected]
Phone (toll free): +1 888-959-8091
In addition, you have the right to make a complaint about the way we process your personal information to:
- the Data Protection Commission (DPC), Ireland’s supervisory authority for data protection matters and/or
- to the local privacy regulator in California.
We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority or the local privacy regulator, so please feel free to contact us in the first instance.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
The Site and App may include links to third-party websites, plug-ins and applications ("Third Party Sites"). 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 Sites and are not responsible for their privacy statements. When you leave our Site or App, we encourage you to read the privacy notice of every Third Party Site you visit or use.
Personal information, means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include data where the identity has been removed (de – identified data).
We may collect, use, store and transfer different kinds of personal information about you which we have grouped in categories as follows:
|Category of Personal Information||Specific Pieces of Personal Information|
|Marketing and Communications Data||
As explained above under Identity Data, we will also collect a visual image of your face which we will use, in conjunction with our sub-contractors, to check your identity for onboarding purposes. This data falls within the scope of special categories of data (see Special Categories of Data below). When we ask to collect a visual image of your face you will be asked for your specific consent. You can refuse to provide this, but it means that we will be unable to register you and provide you with the Services.
Special categories of personal information are data revealing your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data. We will only use special categories of personal information for a specific purpose and if we are able to satisfy both the Lawful Basis requirements, as well as at least one of the following additional conditions:
- You have given explicit consent;
- Processing relates to personal information which are manifestly made public by the data subject;
- Processing is necessary for the establishment, exercise of defence of legal claims, or
- Processing is necessary for reasons of substantial public interest based on EU or EU Member State Law.
We are subject to the EU Anti-Money Laundering Directives 4 and 5 and the relevant EU Member States' law implementing them which require us to process for instance information from your ID documents including a photographic picture of you. See also row iv, in the table which describes the purposes for which we will use your personal information.
If you refuse to provide personal information
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you refuse 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 (for example, to provide you services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect information from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal information you provide when you:
- apply for our products or services;
- create an account;
- subscribe to our services or publications;
- make use of any of our Services;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Third parties or publicly available sources. We also obtain information about you from third parties (such as employers, credit reference agencies and fraud prevention agencies) who may check your personal information against any information listed on other databases.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- For the provision of the Services.
- 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 obligation.
- For business purposes we disclose your personal information as described in Section Disclosures of your personal information.
- Sale of Personal Information
When you use our Services, our authorized partners may collect categories of Personal Information about you and use this data for their own purposes. This activity may qualify as a sale under the CCPA. You can make choices to allow or prevent such uses. Depending on your choices, during the past twelve months, we may have sold information within the categories defined in the table under Section 2.
Generally, we do not rely on consent as a legal basis for processing your personal information although we will get your consent before 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. See below for further details on marketing.
Purposes for which we will use your personal information
We have set out below, in a table format, an illustrative example of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information on 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 ground, we are relying on to process your personal information where more than one ground has been set out in the table below.
|No||Purpose/Activity||Categories of personal information||Lawful basis for processing including basis of legitimate interest|
|i.||To register you as a new customer||
|v.||To enable you to partake in a prize draw, competition or complete a survey||
|vi.||To administer and protect our business, our Site and App(s) including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data||
|vii.||To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|viii.||To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||
||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to form our marketing strategy)|
|ix.||To make suggestions and recommendations to you about goods or services that may be of interest to you||
||Necessary for our legitimate interests (to develop our products/services and grow our business)|
Relevant for individuals related to partnering companies
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Transactional, Usage and Profile Data 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or sending a message to [email protected].
When you opt-out of receiving these marketing messages, this will not apply to messages related to a product / service transaction, maintenance of our systems or product / service experience.
Change of purpose
We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may share your Personal Information with our third-party service providers, agents, subcontractors, and other associated organizations, our group companies and affiliates in order to complete tasks, provide the Services to you on our behalf, and otherwise fulfill our obligations. We require third-party service providers, under written agreements, to respect the security of your Personal Information and to treat it in accordance with applicable law.
We may share your Personal Information and other data you provide to us for the following purposes:
- To verify your identity.
- To detect and prevent fraud, money laundering, terrorist financing, and other financial crimes and illicit activities.
- To facilitate the provision of services and relevant business operations to support our delivery of the Services and related aspects to you.
- To improve our information, technology, and security systems including websites and mobile applications.
- To provide customer service.
- To promote our products or Services if you submit a product review or post content on public areas of our product, Services, or social media accounts.
- To transfer our rights and duties under the relevant terms and conditions governing the use of any Services (to the extent allowed).
- To comply, in our belief, with a legal request or to protect or enforce our rights, including to comply with an applicable law or regulation, or in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability, and to protect the rights, property, and safety of us or others.
- To evaluate, effectuate, or otherwise transfer your Personal Information as part of a proposed or actual sale, merger, restructuring, transfer, or exchange of all or a portion of our assets to another company.
We may have disclosed or sold the following categories of Personal Information to the following categories of third parties
|Categories of Third Parties||Categories of Personal Information|
|Companies and organizations that assist us in processing, verifying or refunding transactions||Identity Data, Financial Data, Transaction Data|
|Identity verification agencies||Identity Data|
|Fraud prevention agencies||Identity Data, Financial Data, Transaction Data|
|Organizations which assist us with customer service facilities;||Identity Data|
|Anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant Terms & Conditions governing the use of any of the Services;||All the categories in the table under Section 1 above.|
|Regulatory and law enforcement authorities, where the law allows or requires us to do so.||The categories would depend on legal grounds of the request.|
Considering the nature of customers’ on-boarding verification process, we do not have an actual knowledge of selling Personal Information of minors under 16 years of age.
To learn more about International Transfers, please click here.
To learn more about International Transfers, please click here.
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transactional Data) for at least 5 years. For example, under the EU Anti-Money Laundering legislation (Anti-Money Laundering Directives 4 and 5) we are obliged to retain your personal information for a period of 5 years after the end of the relationship between us as a company and you as a customer.
For the purpose of defending our legitimate interests against possible legal claims, please note that correspondence (e.g. email addresses and content, chats with the customer service team, call recordings etc.) will be kept up to 10 years, depending on the limitation period (a limitation period is a time period during which a claim can be made) applicable in your country, after the end of the relationship between us as a company and you as a customer.
Another example relates to our legitimate business need to prevent abuse of the promotions that we launch. We will retain a customer’s personal information for the time of the promotion in order to prevent the appearance of abusive behavior.
Please note that under certain condition(s), you can ask us to delete your personal information. In some circumstances we will de-identify your personal information (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.
Under certain circumstances, you have rights under applicable law in relation to your Personal Information:
- Right to know about Personal Information collected, disclosed, or sold. ("Verifiable Consumer Request to Know").
- Request correction of your Personal Information.
- Request erasure / deletion of your Personal Information. ("Verifiable Consumer Request to Delete").
- Right to opt-out of the sale of your Personal Information.
We will promptly take steps to disclose and deliver to you, free of charge, your Personal Information according to your Verifiable Consumer Request to Know. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not receive a discriminatory treatment if you choose to exercise any of the rights conferred to you above.
Under certain circumstances, you may have rights under applicable law in the European Union, please click here.
If you want to make a request under the California Consumer Privacy Act through a natural person or a business entity authorized to act on your behalf, please beforehand contact us and in a timely manner we will provide you with a reply on how to designate such a person.