Last updated: 12/03/2021
For the purposes of this documents Globepay Services consist of products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by us through mobile apps, online platform,official social media platforms, or other online properties through which we provide payment and e-money services.
Globepay Service is designed for business purposes and may be used by individuals or entities. In case you are registering for and/or using Globepay Services on behalf of an entity we will treat you as authorized person and you may be obliged to disclose to us personal data of the legal representatives, the employees, the agents, the beneficial owners or any other third-party related to the entity pursuant to the rules described below. You certify that where you have provided information regarding any third person beside yourself you have received prior consent from that other person to provide their personal information to us.
You are informed that there are three general categories of information that is collected from you differentiated on grounds as defined by the UK General Data Protection Regulation and The Data Protection Act 2018.
1.1 Information that we collect in order to perform our legal obligations and in order to provide Globepay Service as part of our contract with you.
We ask for and collect from you the following personal information when you use the Globepay Service. This information is necessary for us to comply with our regulatory obligations and for the adequate performance of the contract between you and us. Without it, we may not be able to provide you effectively with Globepay Service for which you register
1.2 Information that we collect with your consent.
You may choose to provide us with additional personal information when you fill in a form, conduct a search, update or add information to your Globepay Account, respond to surveys, participate in promotions, or use other features of the Globepay Service. This additional information will be processed based on your consent.
1.3 Information We Collect from Your Use of the Globepay Service
Please be advised that when you use Globepay Service, we automatically collect some of the personal information described in the sections above such as Geo-location Information, Log Data and Device Information, Cookies and Similar Technologies, Payment Transaction Information. This information is necessary given our legitimate interest in being able to provide and improve the functionalities of the Globepay Service
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop Globepay Service, create and maintain a secure environment, pursue our legitimate interests and comply with our legal obligations.
2.1 Provide, improve and develop the Globepay service
We process this information given our legitimate interest in improving the Globepay Service and our clients’ experience with it, and where it is necessary for the adequate performance of the contract with you as well as to comply with applicable laws.
2.2 Create and maintain a secure environment
3.1 With third party service providers: We may share personal information with third party service providers that support us in providing Globepay Service, products and/or Platform with functions at our decision and our behalf.
These third-party service providers may for example:
3.2 With other third parties for our legitimate interest or as permitted or required by law: We may share information about you with other parties for our legitimate interest or as permitted or required by law, including:
With your consent: We will also share your Personal Data and other information with your consent or direction, including if you authorise an account connection with a third-party account or platform.
3.3 Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
3.4 We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer services or training purposes. When visiting our offices, CCTV, access control systems and/or other monitoring systems may be in operation.
You may exercise any of the rights described in this section before the respective Data Controller pursuant to the Legal Agreements by sending an email from your e-mail registered for Globepay Service to the respective Company providing the Service to you under the respective Legal Agreement stated below. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.
4.1 Managing your information
You have the right to obtain the following:
Confirmation of whether, and where, we are processing your personal data;
Information about the purposes of the processing;
Information about the categories of data being processed;
Information about the period for which the data will be stored (or the criteria used to determine that period);
Information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing;
4.2 Rectification of inaccurate or incomplete information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself via your online access to Globepay Account).
4.3 Data access and portability:
You have the right to:
4.4 Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations. If you no longer want us to use your information to provide Globepay Service to you, you can request that we erase your personal information and close your Globepay Account, providing your account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevent us by law to close your account or terminate the Service. Because we are a regulated financial institution under FCA, we are obliged under PSD and AML laws to keep your personal information and all transaction history for a period of 5 years after the termination of the relationship with you. Please note that if you request the erasure of your personal information:
4.5 Withdrawing consent and restriction of processing
Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where
(i) you contest the accuracy of your personal information;
(ii) the processing is unlawful and you oppose the erasure of your personal information;
(iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or
(iv) you have objected to the processing and pending the verification whether our legitimate grounds override your own.
4.6 Objection to processing
In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise or defence of legal claims. Please note that we are obliged under AML laws to make risk profiling of our customers upon opening of the relationship and constantly during the relationship and this is a legitimate reason. In case you do not wish us to process your personal data for certain specific purposes, which are legitimate purposes to us, you shall have to close your account or we may have to stop providing you some or all of the Services, subject to all conditions for the closing of the account, specified above in this Section.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to the contact e-mail below.
4.7 Lodging complaints
Data Protection Officer: Tamar Tappin
Address: Level 30, Landmark, 40 Bank Street, London, E14 5NR
4.7.2 Competent Regulator. In case you are not satisfied with the reply or resolution of the respective Data Controller, you have the right to lodge complaints about the data processing activities carried out by us before the competent data protection supervisory authorities as described below.
Information Commissioner’s Office
5.1 Other means to ensure an adequate level of data protection
In case personal information is shared with corporate affiliates or third-party service providers outside the EEA in absence of an adequacy decision, we have – prior to sharing your information with such corporate affiliate or third-party service provider – established the necessary means to ensure an adequate level of data protection. We will provide further information on the means to ensure an adequate level of data protection on request.
We take the responsibility to ensure that your personal information is secure, kept in an encrypted form on servers, collocated in Special data centres in Class A jurisdictions in Europe. To prevent unauthorized access or disclosure of information we maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard non-public personal information. Once you are logged into your Account, all internet communication is secured using Secure Socket Layer (SSL) technology. We restrict access to your personally identifiable information only to employees who need to know that information in order to provide products or services to you.
If you know or have reason to believe that your Globepay Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Globepay Account, please contact us following the instructions in the Contact Us section below. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.
Globepay Service is not designed to individuals under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use Globepay Service. If we obtain actual knowledge that we have collected Personal Data from an individual under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact usif you believe that we have mistakenly or unintentionally collected information from an individual under the age of 18.