Privacy Policy

Introduction

This website (“Website”) is operated by GlobePay Limited (“GlobePay”, ”we” or “us”) and we are committed to protecting and respecting your privacy.

This Privacy Policy (together with our Terms of Service and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following carefully to understand our practices regarding your personal data.

For the purpose of applicable data protection legislation, the data controller is GlobePay Limited, registered address: 23 Franklin Building, 10 Westferry Road, London, England, E14 8LS.

1. Definition

Personal information (or “personal data”) is information that can be used to identify an individual, directly or indirectly. We may also collect non-personal information, or may anonymise personal information so that it no longer identifies an individual. Non-personal information may be collected, stored, used, transfered and disclosed for any purpose, for example, the use of aggregated transactional information used for analytical or commercial purposes.

2. Information we collect from you

We will collect and process the following data about you:

Information you give us.

This is information about you that you give us by filling in forms on our website globepay.co (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service(s), search for a product, and when you report a problem with our site. The information you give us may include your name, date of birth, address, email address, phone number, financial and bank account information, personal description, and photograph. If you give us information on behalf of someone else, you confirm that you have given them the information set out in this notice and that they have given permission for us to use their information as set out in this notice.

Information we collect about you.

With regard to each of your visits to our site we will automatically collect the following information:

1. technical information, including the Internet protocol (IP) address;
2. information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products 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, and any phone number used to call our customer service number.

Information we receive from other sources.

Where we obtain personal data from third-party sources (such as credit reference agencies, sanctions or fraud-prevention databases, or public available sources), we will ensure that appropriate notice is provided to you in accordance with applicable data protection law.

3. Uses made of the information

What processing grounds do we rely on?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where you have given us your consent (for example, to send you marketing communications or to place non-essential cookies on your device).
• Where we need to perform the agreement, we are about to enter into or have entered into with you (for example, to provide you with any products and/or services which you have requested);
• 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 (for example, detecting suspicious activity, improving security of our systems, and undertaking analysis and research for the purposes of improving our website user experience); and
• Where we need to comply with a legal or regulatory obligation, including anti-money laundering (AML), counter-terrorist financing (CTF), Know Your Customer (KYC), fraud prevention, and other statutory or regulatory reporting obligations.

Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

We use information held about you in the following ways:

Information you give to us. We will use this information:

• to carry out our obligations arising from any agreements entered into between you and us 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 provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not wish to receive marketing communications, you may withdraw your consent or update your preferences at any time by using the unsubscribe option provided in our emails and the cookies setting tool on our Site;
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site 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 site about goods or services that may interest you or them.

Information we receive from other sources. 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 for the purposes set out above (depending on the types of information we receive).

4. Disclosure of your information

You agree that we have the right to share your personal information with selected third parties including:

• business partners, suppliers, and sub-contractors for the performance of any agreement we enter into with them or you;
• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
• analytics and search engine providers that assist us in the improvement and optimisation of our site;
• credit reference agencies for the purpose of assessing your credit score;
• compliance vendors for the purpose of identifying and verifying your information,where this is a condition of us entering into an agreement with you;
• fraud-prevention and sanctions-screening service providers, where required to comply with our legal and regulatory obligations.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If GlobePay 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 obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of GlobePay Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and risk management.

5. Your rights

Under the UK GDPR, you have the following rights in relation to your personal data:

• Right of access – to obtain a copy of the personal data we hold about you.
• Right to rectification – to correct inaccurate or incomplete data.
• Right to erasure – in certain circumstances, to request deletion of your data.
• Right to restrict processing – to request that we limit how your data is used.
• Right to object – including to processing based on legitimate interests or for direct marketing.
• Right to data portability – to receive your data in a commonly used, machine-readable format.
• Right to withdraw consent – where processing is based on consent.
• Right not to be subject to automated decision-making – including profiling that has significant effects.

How to exercise your rights?

You may exercise any of these rights by contacting us at: info@globepay.co. We may need to verify your identity before responding to your request.

Right to Complain

You also have the right to lodge a complaint with the UK supervisory authority Information Commissioner’s Office (ICO) www.ico.org.uk

6. Where we store your personal data

The data that we collect from you may be transferred to and stored in countries outside the United Kingdom and/or the European Economic Area (EEA). Where we transfer your data outside the UK, we will ensure that an adequate level of protection is in place, such as by relying on adequacy regulations issued under the UK GDPR or implementing the International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, as appropriate.. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where we have given you (or where you have chosen) a password or access code which enables you to access certain parts of our site, you are responsible for keeping your login credentials confidential. You should not share these credentials with anyone, and GlobePay will not be liable for any unauthorised access resulting from your failure to safeguard them.

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 site; 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.

7. Third party websites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

8. Cookies

For detailed information about the cookies we use and your choices in relation to cookies, please refer to our Cookies Policy.

9. Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including (1) to comply with applicable law; (2) provide the GlobePay services, and; (3) pursue our legitimate interests, including detecting and preventing fraud and financial crimes, enforcing and defending our legal rights, complying with valid legal process requests from courts or competent authorities, improving the quality of our services, and promoting our products and services as appropriate and as permitted by applicable law and agreements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

GlobePay will generally keep Personal Data we obtain for at least five years from the end of the business relationship with you, or the date of the last transaction, whichever is later, in accordance with applicable financial services and anti-money laundering record-keeping requirements. We may also hold your personal information for longer where it is necessary to do so for the management of any active or potential legal proceedings, to resolve or defend claims, and for the purpose of making any necessary remediation payments.

10. Changes to our privacy policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Changes will take effect when posted unless a later effective date is indicated. Please check back frequently to see any updates or changes to our privacy policy.