Effective Date: 2021/08/01
This Privacy Notice describes the types of Personal Information we collect, the purposes for which we collect that Personal Information, the other parties with whom we may share it and the measures we take to protect the security of the data. It also tells you about your rights and choices with respect to your Personal Information, and how you can contact us about our privacy practices.
Please note that we also act on behalf of and under the instructions of financial institutions, merchants and other partners which act as data controllers, including for processing payment transactions. Please refer to their respective privacy policies for more information regarding the processing of your Personal Information in these contexts.
Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Specific privacy notices may apply to some of our products and services. Please visit the webpage or digital asset of the specific product or service to learn more about our privacy and information practices in relation to that product or service.
Personal information we may collect
"Personal Information" means any information relating to an identified or identifiable individual. We may collect the following categories of Personal Information:
- Transaction information, such as personal account ID, the merchant’s name and location, the date and the total amount of the transaction, and other information provided by financial institutions or merchants when we act on their behalf.
- When you visit our Sites we may collect certain non-identifiable information via cookies, web beacons, and other similar tracking technologies to help us enhance your Site user experience
- Business contact information when you contact us or request that we contact you
- Job applications and related information when you apply for a job with us
How we use your personal information
We will only use your personal information when we have a legitimate basis, including to:
- Process your payment transactions.
- Provide you with the products, services, programs, offers, or information you request from WalletsClub, and for related purposes such as determining eligibility and customer service.
- Manage our business needs, such as monitoring, analyzing, testing and improving our products and services, the Sites’ performance and functionality and the performance and functionality of our infrastructure;
- Process your job application.
- Carry out our obligations that may arise from any agreements we have entered into with you or your financial institution or other third parties
- Comply with legal and regulatory requirements
Please note that we may also use and disclose information that is not personally identifiable. For example, we may publish reports that contain aggregated or statistical data, such as reports showing general payment usage trends. These reports do not contain any personal information.
How we share your personal information
We do not disclose Personal Information we collect about you, except as described in this Global Privacy Notice, as disclosed to you at the time of data collection or as described in our program specific privacy notice. We may disclose your personal information with：
- Other participants in the payment ecosystem, including financial institutions, and merchants.
- Other participants in the Open Banking ecosystem, including financial institutions, merchants and third parties.
- Third parties for fraud monitoring and prevention purposes, or other purposes required by law.
- Other entities as required under applicable law or in the event of a sale or transfer of our business or assets.
- Government institution that has asserted its lawful authority to obtain the information if we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity or to legal authorities
Your rights and choices over your personal information
Depending on your country, you are entitled to certain rights over your own personal information, as listed below:
- Right of access – You have the right to be informed of the existence, use and disclosure of your personal information by us, and have access to that information (including a listing of the third-party organisations with whom the information has been shared).
- Right to rectification of errors – When you demonstrate the inaccuracy or incompleteness of your personal information held by us, we must correct the inaccuracies and/or add a notation to the information, as appropriate.
- Right to challenge accuracy – You have the right to challenge the accuracy, completeness and currency of your personal information in our possession.
- Right to limit use of personal information – As a condition of providing you access to an WalletsClub product or service we cannot require that you allow us to process your personal information beyond that which is required to fulfill the explicitly specified and legitimate purpose.
- Right to withdraw consent – You are able to withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. We must inform you of the implications of such withdrawal.
- Right to object to marketing – You must consent to our collection, use or disclosure of your personal information for marketing purposes.
- Right to complain to the relevant data protection authority(ies) – You have the right to be able to address data protection issues with our Privacy Office and you also have the right to make a complaint to the relevant data protection authority.
International data transfers
WalletsClub is a global business. We may transfer your Personal Information other countries which may not have the same data protection laws as the country in which you initially provided the information, but we will protect your Personal Information in accordance with this Global Privacy Notice, or as otherwise disclosed to you.
How we protect your personal information
We use physical, technical, organizational, and administrative safeguards to help protect your personal information from unauthorized access or loss. For example, we use encryption and other tools to protect sensitive information. We retain your personal information as needed for the purposes listed above and as permitted by law.
Updates to this privacy notice
WalletsClub may review this Privacy Notice periodically to reflect changes in privacy regulations and in our practices. We will post a prominent notice of any relevant and material changes to this Privacy Notice when they occur and indicate when this Privacy Notice was most recently updated.
If you have questions or comments about our privacy practices, or if you would like help exercising your privacy rights, please contact us. You can Email us: firstname.lastname@example.org
Please do not include sensitive information, such as your account number, in emails.