Dated May 2018
1. SCOPE OF POLICY
1.1 Glint is determined to protect and respect your privacy. We are registered with the Information Commissioner’s Office under number ZA201362.
This policy applies to your use of:
a) our website at www.glintpay.com (the ” Site”)
b) the Glint app (app) once you have downloaded a copy of the app onto your mobile telephone or handheld device (Device); and
c) any of the services accessible through the app or the Site (the Services)
1.2 This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
1.3 When we say “we”, we mean Glint Pay Services Limited who is the “Data Controller” for the information in this document. This means we are responsible for letting you know how we use your information.
2. INFORMATION WE COLLECT FROM YOU
2.1 We will collect and process the following data about you:
a) Information you give us (submitted information): This is information you give us about you by registering on the app and/or the Site, or by corresponding with us (for example, by e-mail or via the app and/or the Site). It includes information you provide when you register to use the app, download or register the app, subscribe to any of our services, enter into any transaction on the app or the Site such as a Top Up, Bank Transfer, withdraw, enter a competition, promotion or survey and when you report a problem with an app, the Services, or the Site. If you contact us, we will keep a record of that correspondence.
b) Information connected to your usage of our product, technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
c) Details of all transactions you make with us including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant or ATMs associated with the transaction, and any other information you provide us to prove your eligibility to use our services.
d) Information about you and your device. Each time you visit the App or our Site we will automatically collect the following information:
• information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services 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, device information and any phone number used to call our client service number;
• information from your address book, and login information.
e) Location information. We use GPS technology and your IP address to determine your location. This is used to prevent fraud, for instance if your mobile phone is saying that you are located in the UK, but your card is being used in Spain, we may not allow that transaction to be processed. Our card protection and fraud-prevention measures require this personal data for the feature to work.
If you wish to use this feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by de-selecting “location-based security” on the Card Security part of the App
f) Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, fraud prevention agencies, customer service providers, developers, social media organisations such as Facebook, Twitter and/or Google).
3. HOW WE USE THE INFORMATION
3.1 We use information held about you in the following ways:
• to carry out our obligations arising from any transactions you enter into with us, for example Top Ups, Bank Transfers, Withdrawals, ATM Withdrawals and Glint Card Purchases and to provide you with the information, products and services that you request from us;
• to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services; and to comply with our regulatory obligations.
• to notify you about changes to our service;
• to administer our Site and the app for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• as part of our efforts to keep our Site and the app safe and secure;
• to measure or understand the effectiveness of our communications with you.
3.2 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
3.3 We will not disclose information about identifiable individuals to third parties, but we may provide them with anonymous aggregate information about our users for the purposes of;
• the improvement and optimisation of our site by using analytics and search engine data;
• third parties to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services.
3.4 We will disclose your personal information to third parties:
• If Glint or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients 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 or regulatory obligation or request.
4. WHERE YOUR DATA IS STORED
The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for Glint or for one of our suppliers.
5. YOUR RIGHTS
• You have a number of rights relating to your information. This includes the right to access the personal data we hold about you, to ask us to update incorrect or incomplete details, to object or restrict the processing of such data or to obtain a copy of it.
• You have the right to withdraw your consent for us to use your data at any time.
• We will only keep your personal information for as long as you have a relationship with us. After that relationship ends, we may need it for legitimate purposes such as responding to queries, complaints, requests from regulators or for other reasons related to financial crime investigations. Otherwise we will then delete it securely and safely.