At a time of extraordinary monetary policy and when trust in currencies, banks and existing payment systems has been eroded.
Glint helps us move to a more just, sustainable and inclusive global economy

info@glintpay.com

Privacy Policy

1     Introduction

02/08/2017

Here at Glint (Glint Pay Services Ltd) we take the privacy of your personal information very seriously. All data we collect, transfer, process and maintain is done in accordance with the Data Protection Act 1998 of the United Kingdom and the Privacy and Electronic Communications (EC Directive) Regulations 2003. Here in this Privacy Policy you will find details of all the personal information we collect, use and disclose in order to operate our business and deliver the services we offer.

We recommend having a good look through the policy. When you deal with us as a business and share your personal information with us, it means you expressly consent to us collecting, using and disclosing your personal information in the ways we have described here. So if you object to your personal information being collected, used or disclosed in these ways, you should not use Glint payment services, either on the app or website.

(in order to be clear, where this document mentions the Glint website you should assume we are referring to the app as well).

2     Links

This document only covers Glint’s policy towards your privacy. We’re not responsible for the ways our registered merchants process information or any other aspects of their operations. If you submit information to, or through, these third party websites, you should take a look at the privacy statement for those sites before providing them with personally identifiable information. Thy will be governed by their own privacy statements which could differ from our own.

3     Personal Information

When we refer to ‘personal information’ or ‘personally identifiable information’ in this privacy policy, we mean information about you that can be attributed to you. Any personal information we collect, use and disclose is done in accordance with the terms laid out here in the policy.

Sometimes the way we treat personal information is authorised by law, while at other times it is with your consent. Depending on the circumstances, that consent might be expressly given or implied.

Express consent arises when you specifically consent to the treatment of your personal information in some way – it might be given orally, electronically (by acknowledging a check box on a webpage) or in writing. Implied consent can be inferred from the circumstances, taking into account the reasonable expectations of clients and the sensitivity of the information. If Glint needs to collect, use or disclose any information for any purpose that isn’t set out here in this privacy policy, we will give you appropriate notification and ensure you have the chance to object or decline.

If you have questions or concerns about any of these issues, you should contact the Customer Support Team – you’ll find contact details at the end of this document.

4     Notification of Changes

We may change this privacy policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, giving you additional notice (such as adding a statement to our homepage or sending you an email with details).

Any amendments will be effective from the time of posting By continuing to use our service it is taken that you expressly consent to those changes. If you disagree with any amendments, you may close your Account and/or stop using the service at any time.

5     Collection of Information

What information do we collect directly from you?
When you sign up for Glint, we are required by law to verify your identity. We also need to collect various types of information to establish and maintain your account. As a result, we ask for:

  • Name
  • Email address
  • Phone number
  • Permanent address and/or mailing address
  • Date of birth
  • Bank account number, sort-code and IBAN
  • Credit card number
  • Debit card number

Occasionally, your passport and driving license information too. We also collect information from you when you register on our site, subscribe to our newsletter, or respond to a survey.
This information is required to ensure that we can:

  • Process transactions;
  • Issue a new passcode if you forget or lose your existing one
  • Protect you, Glint and our other clients, against identity theft, credit card fraud and bank account fraud
  • Contact you about administering your account.

Transaction Information
Transaction information relates to any information required to send or request a payment. This may include: the amount of the transaction, the type of transaction, the bank and bank account details, e-mail address, phone number of the payee or beneficiary involved in the transaction.

We may sometimes retain a third party’s contact details, if they are necessary to provide our services or fulfil our legal obligations.

For fraud and/or security purposes, we may retain your personal information, including transaction information for all of your transactions through Glint, for a number of years even after your account is closed or you have stopped using the service.

We also collect the Internet address (IP address) of the computer or device you use to access your Account, in order to help detect possible instances of unauthorised transactions.

Information About You Provided by Third Parties
In order to protect all our clients and Account Holders against potential fraud, we may choose to verify the personal information that you provide with third party verification service providers. In doing this, we may also receive personal information about you from those service providers. In particular, if you register a debit or bank account with Glint, we will, wherever possible, use card authorisation, authentication and fraud screening services to verify that your card information and address matches the information that you supplied to Glint, and that the card has not been reported as lost or stolen.

If you incur a debt to Glint, we may conduct a credit check on you by obtaining additional information about you from a credit reference agency, to the extent the law allows. Glint, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account. We also reserve the right to close and or refuse to provide a payment service based on information obtained in this way.

Web Site Information
Because of the way that online communication standards work, when you arrive at or leave the Glint website, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our website you visit while you are on the Glint site. We use this information only to try to understand our clients and account holders’ behaviour and preferences, to develop and improve our services to you, and to manage the load on our servers. We do not track the websites you visit before or after you leave the Glint site.

Use of Cookies and other Tracking Technologies
We use various technologies to collect and store information related to your use of our services. This is to personalise our services and to collect information about usage that will help them improve them.

We may collect and store information locally on your device, and we may also use cookies – small files that a site or its service provider transfers to your computer’s hard drive through your browser (if you agree) that enables those systems to recognise your browser and remember certain information.

We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our service or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Most browsers allow you to turn off cookies. If you want to know how to do this please look at the help menu on your browser. However, switching off cookies may severely restrict your use of the Glint service and many other sites.
For independent advice on how to deal with cookies go to www.aboutcookies.org

Customer Service Correspondence and Phone Calls
If you send us correspondence, including e-mails and faxes, we will retain information about that in the records of your account. We will also retain any correspondence from Glint to you. We keep these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our Terms of Use. Any phone calls made to or from us may be monitored and/or recorded for quality assurance purposes, and security and fraud detection purposes.

Questionnaires, Surveys and Profile Data
From time to time, we may offer you optional questionnaires and surveys to collect demographic information, assess client’s interests and needs and evaluate user’s experience of the Glint service. If we collect personal information from you in this way, we will tell you how the information will be used before you get started. The opt-out procedure’ is described in the section on managing marketing communications from us.

6     How We Use Collected Information

We may use information about you for a range of purposes. These might include:

  • Providing, maintaining and improving our services
  • Sending you technical notices, updates, security alerts and support and administrative messages
  • Responding to your comments, questions and requests
  • Monitoring and analysing, how you use our services
  • Meeting the requirements of any applicable law, regulation or legal process,
  • Investigating fraud inside and outside the Glint services
  • Providing you with customer support when things go wrong
  • Providing you with processing and tracking your transactions
  • Improving and building features and services you or other clients may want
  • Minimising fraud and abuse of out services
  • Communicating with you about changes in our services, the status and security of your account and data, and administrative information.
  • Directly marketing to you products and features
  • Providing you with offers and deals from third parties
  • Performing internal marketing analytics
  • Providing you with gifts as part of your use of our services

We give access to your personal information only to those employees who require it to provide our services to you.

Internet Address Information
We use IP addresses, browser types and access times. We do this to analyse trends, administer the site, improve site performance, gather broad demographic information for aggregate use, and to prevent fraud.

Disclosure to Third Parties
Glint won’t sell or rent any of your personal information to third parties.
Glint will not share any of your personal information with third parties except in certain circumstances described below, as permitted by applicable law, or with your express permission. If this happens, these third parties are limited by law or by contract from using the information for secondary purposes.

  • We share information with companies that help us process the transactions you request and protect transactions from fraud, such as sharing your card number with a service that screens for lost and stolen card numbers. If you go into a negative balance and owe us money, we may share information with processing companies including debt collection agencies.
  • In order to assist us in conducting or co-operating in investigations of fraud or other illegal activity – or in order to assist us in investigating suspected violations of our Terms of Use – we may disclose personal information to third parties where reasonable and appropriate.
  • We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
  • We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
  • To validate and verify your identity, the following information may be provided to merchants or banks who you transfer funds to, or who transfer them to you: name, account number, jurisdiction, postal code, email address, and/or IP address.
  • We may disclose information to service providers who manage various marketing or development programs on our behalf. Your personal information will be provided under a strict code of confidentiality. If we transfer your information to a service provider in another country, we will make sure that the service provider agrees to apply the same levels of protection as we are required to apply to information held in the UK and to use your information only to provide the service to us. These third parties are limited by law or by contract from using the information for secondary purposes.
  • As with any other business, it is possible that Glint in the future could amalgamate or merge with or be acquired by another company. If such an event occurs, the successor company would have access to the personal information maintained by Glint, including client account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in the Section above.
  • We share your information with our parent, subsidiaries and joint ventures to help co-ordinate the services we provide to you and to enforce our Terms of Use.
  • Please note that some banks and merchants may operate from countries outside of the EU where data protection laws are less stringent. By accepting this Privacy Policy, you expressly consent to the exchange of some of your personal information between Glint and these banks and/or merchants.Client Contact
    We communicate with clients on a regular basis via e-mail and, in the future, may use ‘live chat’ or a similar service, to provide requested services. We may also communicate by phone to resolve complaints, investigate suspicious transactions or to inform you of changes to our service or accept instructions regarding your account. We use your email address to confirm your opening of a Glint account, to send you notice of payments that you send or receive through your account, to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, clients and account holders cannot opt out of these communications, but they will be primarily informative in nature rather than promotional.Marketing Communications
    We use your email address to send you various types of communications that you can control, including marketing communications, surveys and questionnaires, and notice of special promotions from Glint or its carefully selected business partners. These promotions will relate to similar products and services to those offered by Glint but, out of respect for your privacy, you can choose not to receive them. An explanation of how to do this will be contained within each promotional email that you receive. By agreeing to Glint Terms of Use you will also be indicating your consent to receiving promotional emails.

7     Your Use of Information Obtained from this Site

By accepting this Privacy Policy, you agree to only use any personal information you may have obtained from the use of our services for Glint related communications, and not for any unsolicited commercial communications.

8     How We Store Collected Information

Information Security and Protection
Glint is committed to using high standards of information security when handling your personal information. Any debit or credit card and bank account information is stored on computers that are not connected to the Internet. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We also maintain physical, electronic and procedural safeguards that comply with regulations to guard your non-public personal information. We test our security systems regularly and also have our security systems and processes audited and tested by outside companies.
We protect your information from error, loss, and unauthorised access. Employees who have access to your information are made aware of how to keep it confidential, and each of them must sign an agreement stating that maintaining confidentiality is a condition of their employment with Glint.. All of your personal information is collected, used, and disclosed for business purposes only.

Securing your Personal Information
Security is extremely important to us. We take all reasonable measures to protect information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction, including industry standard security and encryption features.

In the unlikely scenario that your personal information is compromised due to a data breach, we will take all reasonable steps to remedy the breach and notify you as soon as possible.

Despite our efforts to keep your information secure, we cannot guarantee the security of your information. As a result, we strongly encourage you to take action to protect your personal data and any device you use to access our services. In the unlikely event that we come to learn that either our system or your account specifically has suffered a security breach, we may attempt to notify you electronically so that you can take appropriate steps, by email, text message, phone call, a notice on the website, or any other way, depending on the legal requirements that apply.

Your Responsibility
The security of your use of the Glint service also relies on your protection of your Glint security identification. You should never share your password with anyone. Glint will never ask you to send your password to us in an e-mail, although we may ask you to enter this and other personal information on the Glint website, which will always have a URL beginning with https://www.glintpay.com.

Phishing
Any e-mail or other communication asking you to provide personal information via email, or linking to a website with a URL that does not begin with https://www.glintpay.com/ should be treated as unauthorised and suspicious and should be reported to Glint immediately. If you do share your password with a third party for any reason – including because the third party has promised to provide you additional services such as account aggregation – the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your security identification or password, please contact us right away as described in the section below.

9     Updating Your Information

You can review the personal information you’ve shared with us and make any desired changes to this and your account settings at any time. You can do this by logging into your account at https://www.glintpay.com and navigating to ‘my profile’ page.

If you close your Glint account or cease being a client of Glint payment services, we will mark your account in our database as ‘Closed’ but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account.

However, if you close your account, your personally identifiable information won’t be used by us for any further purposes. It won’t be sold or shared with third parties either, except if this is necessary to prevent fraud and assist law enforcement, we’re required by law.

At your request, Glint will also share with you where your personal information has been stored, what personal information Glint has about you, for what purposes Glint uses it for and with whom we’ve shared it with.

Deleting Your Account
If you no longer wish to use Glint services and would like to delete or deactivate your account, please contact us. We are required by law to retain your information, and may also do so for legitimate business purposes, but we will not share or use your information for promotional and marketing purposes after you have deleted or deactivated your account.

As stated above, your usage of our services is contingent on your expressly opting in to this Privacy Policy. If you change your mind after agreeing and wish to opt out at a later date, you must contact us to cancel your account. You can do so by deactivating your account in the app. If you cancel your account, we will not use or share your information for marketing or promotional purposes, except in an anonymised or de-identified form.
However, please be aware that even if you do cancel your account we’re required by law to retain your information and may retain it for legitimate business purposes, including internal analytics.

10     Contact us

If you have any questions about this privacy policy, Glint information practices, or your dealings with Glint, you can contact us in a number of ways: