We will collect and process the following Personal Information and other information about you:

2.1. Information you provide us:

2.1.1. You may provide us information about you when you sign up to use our Service, e.g., when you provide us with personal details like your name and email address. This also includes information you provide through your continued use of our Services, e.g., by reporting problems with our Services. The information you provide us may include your name, phone number, address, email address, financial information (including credit card, debit card, and/or bank account information), payment details and reason, geographical location, personal identification number, tax identification number, personal description and “selfie” photograph, photograph of your identity document.

2.1.2. In some cases, such as when you send or receive transactions, or where we need to comply with anti-money laundering regulations, we may also require more information from you, e.g., commercial or identification information.

2.1.3. In providing the personal data of any individual (other than yourself) that receive payments from you during your use of our Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal information, for the purposes set out in this Privacy Policy.

2.2. With regard to your use of our Services, we may automatically collect the following information about you:

2.2.1. technical information, including IP address, your login information, browser type and version, time zone setting;

2.2.2. information about your visit, including the full URL; products you viewed or searched for; length of visits to certain pages, page response times, download errors, and methods used to browse away from the page and any phone number used to call our customer support number

2.2.3. details of the transactions you make when using our Services, including geographic location from which the transaction originates.2.3. Information from other sources: we may receive information about you from other sources and add it to our account information, including when you apply to use the Services. For example, we work closely with, and receive information from, third parties like business partners, banks and other financial institutions, merchants, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, government lists and databases, social media sites (including posting made by or about you or us), credit reference and fraud prevention agencies. 2.4. We may also review public comments and opinions made on social networking sites (e.g., Facebook, Google, LinkedIn and Twitter) to better understand our customers and our provision and development of Services.We may aggregate Personal Information. Such aggregated information does not personally identify you or any other user of the Services. For example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code.

3.1. We may use your Personal Information in the following ways:

3.1.1. to carry out our obligations relating to your contracts and transactions with us and to provide you with the information, products and services that you request from us, as well as related customer service;

3.1.2. to notify you about changes to your contracts with us, to our Services or to send you other administrative information;

3.1.3. to administer our Services and for internal operations, including testing, data analysis research, troubleshooting, statistical and survey purposes;

3.1.4. to help us to keep our Services safe and secure;

3.1.5. to improve our Website and to ensure other Services are presented in the most effective manner;

3.1.6. to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;

3.1.7. consistent with choices that may be available to you, to provide you with information about other similar goods and services we offer; and

3.1.8. to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.

3.2. We may also use and disclose Personal Information as we believe necessary or appropriate:

3.2.1. to comply with any applicable legal and/or regulatory requirements, including laws outside your country of residence or domicile;

3.2.2. to comply with legal process;

3.2.3. to prevent and/or detect fraud, financial crime, manage risk and to better protect ourselves, our customers and the integrity of the financial system, it may be necessary to process and disclose sensitive personal information (sometimes known as special category personal data) including biometric data to third parties who help us in managing such risks, including identity verification. This may include software and services we use to verify your identity/age by determining whether a selfie you take matches the photo in your identification document;

3.2.4. during the identification process we may use a facial recognition process to compare your selfie with your uploaded identification document. During this process biometric data is generated by creating a digital map of your face in order to better compare your identification document photo and your selfie photo. This helps to reduce fraud and is therefore in the substantial public interest. But any biometric information generated is immediately deleted following a match. We do not generally store or retain biometric data because such information is generally generated using secure third-party anti-fraud systems. If your biometric information is stored, retained, or used directly by us in any way, you will be notified at the point of collection;

3.2.5. to prevent, detect and prosecute fraud and other crimes and abuses of the financial system, or to assist others in doing so, including non-compliance with any terms of the contract with us and which may involve the sharing of any relevant or necessary information we have collected or inferred with third parties for such purposes. We participate in anti-fraud initiatives, which involve assessing you (and/or your customers) and monitoring your transactions and/or locations, to detect patterns requiring investigations or otherwise profile and assess the likelihood of fraud occurring or non-compliance with our or other’s terms of the contract with us. We can do so utilising products and services from third parties. Additionally, if you give us false or inaccurate information about you, or we identify or suspect a fraud or a crime, we may pass your information to fraud prevention agencies and organisations and to law enforcement agencies and similar bodies, and we may decide to take legal action against you;

3.2.6. to respond to requests from public and government authorities, including public and government authorities outside your country of residence, upon demonstration of lawful authority;

3.2.7. to enforce our contracts with you; 3.2.8. to help to keep our Services safe and secure, including to protect our rights, privacy, safety or property, and/or that of our partners, you or others, and to investigate, prevent, detect or suppress fraud; andto allow us to pursue available remedies or limit the damages that we may sustain.

3.3. We may use and disclose Technical Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Technical Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy. If we combine Technical Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined.

3.4. We may disclose and share your Personal Information with selected third parties including:

3.4.1. recipients/senders of a payment in the context of the specific relevant transaction;

3.4.2. third-party credit and financial Institutions (where allowed under any terms or other contract), including the credit institution where the sender or recipient (and their businesses, respectively) maintain their bank account(s) and the card schemes governing the issue and use of credit, debit, charge, purchase or other payment cards, alternative payment schemes and any other financial institutions who may process payments and who are not operating under our control nor for whose actions or omissions we have liability;

3.4.3. where we provide services through third parties such as banks and other organisations, we may be required to disclose your information (including any “know your customer” and “source of wealth” information) with such organisations in order to assist their own regulatory obligations or risk assessments;

3.4.4. third-party service providers, including suppliers who assist us with the provision of Services, including processing orders, fulfilling orders, processing payments, managing credit, security, sector and fraud risk, identity verification, and marketing, market research and survey activities carried out on our behalf;

3.4.5. affiliates, business partners, joint marketers, suppliers and sub-contractors for the performance of any contract we enter into with them or you;

3.4.6. advertisers and advertising networks solely to select and serve relevant advertisements to you and others;

3.4.7. analytics and search engine providers that assist us in the improvement and optimization of our site;

3.4.8. in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;

3.4.9. to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;

3.4.10. to prevent and detect fraud or crime;

3.4.11. in response to a subpoena, warrant, court order, or as otherwise required by law;

3.4.12. to assess financial and insurance risks;

3.4.13. to recover debt or in relation to your insolvency; and

3.4.14. to develop customer relationships, services and system.

3.5. We make our best efforts to transfer your personal data only to third parties which share our concern for privacy and apply high standards in this respect.

4.1. Data protection laws require to have a lawful basis for using your personal data. The lawful basis we use for collecting and processing your information are as follows:

4.1.1. Where it is necessary for entering into or performing a contract with you;

4.1.2. Where we have a legitimate interest to do so, provided your rights do not override those interests;

4.1.3. Where you have consented to its uses;

4.1.4. Where our colleagues believe it is in your vital interests to share your personal details;

4.1.5. Where required to comply with our legal obligations.

9.1. Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. If you have any questions in relation to our use of your Personal Information, contact us.

9.2. Under certain conditions, you may have the right to require us to:

9.2.1. provide you with further details on the use we make of your Personal Information;

9.2.2. provide you with a copy of the information that you have provided to us;

9.2.3. correct, or update your Personal Information;

9.2.4. delete your Personal Information that is no longer necessary, or no longer subject to a legal obligation to which we are subject to. We have legal obligations so it may not be possible to delete your Personal Information at the time of request. Once the required time has passed then we will be able to comply with your request;

9.2.5. where processing is based on consent, to withdraw your consent so that we stop that particular processing;

9.2.6. object to its processing or temporarily restrict its processing while exercising your other rights. However, objection to any processing based on the legitimate interests ground may be possible unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;

9.2.7. request to transfer certain of your personal information to another service provider;

9.2.8. to opt-out of certain uses of your Personal Information, including asking us to limit the sharing of your personal information with affiliated and non-affiliated third parties.

9.3. Your exercise of these rights is subject to certain exemptions to safeguard the public interest, e.g., the prevention or detection of crime, and our interests, e.g., the maintenance of legal privilege. If you exercise any of these rights we will check your entitlement and respond in most cases within a month.