Effective Date: May 26, 2021
1. SCOPE OF POLICY
- This policy is incorporated by reference into the Platform Terms and any other terms that may be applicable to you and that govern your use of the Services, including but not limited to access to or use of the GMG Mobile App and our Website.
- GMG collects certain Personal Data (defined below) in order to provide our products and Services to you. This policy sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed and disclosed by us. Please read the following carefully to understand our collection, use, and disclosure of your Personal Data.
2. INFORMATION WE COLLECT FROM YOU
- We will collect and process the following data about you:
a) Information you give us (“Personal Data”): This is information you give us about you by filling in forms on the Services, or by corresponding with us (for example, by e-mail or via the chat or support function provided within the Services). It includes information you provide when you register to use the GMG Mobile App, download or register the GMG Mobile App, access or use any of our Services, enter into any transaction using the Services, participate in discussion boards or other social media functions on the Services, enter a competition, promotion or survey, and when you report a problem with the Services. If you contact us, we may keep a record of that correspondence. The information you give us may include your social security number, name, address, date of birth, e-mail address, phone number, the Access Device’s phone number, username, password and other registration information, personally identifiable financial information, details of your bank account including the bank account number, bank routing number, IBAN, details of your debit card including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, driving license and utility bill), and any other information you provide us in order to prove your eligibility to use our Services.
b) Information we collect about you and your Access Device (“Usage Data”). Each time you access or use the Services we may automatically collect the following information:
(i) 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 Access Device or platform you use, date and time stamp, a unique device identifier (for example, your Access Device’s IMEI number, the MAC address of the Access Device’s wireless network interface, or the mobile phone number used by the Access Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting (“Access Device Information”);
(ii) information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our Website (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, the links you click, whether you open emails or click the links contained in emails, device information and any phone number used to call our customer service number, and other actions you take on the Services;
(iii) transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant or ATMs associated with the transaction, IP address of sender and receiver, sender’s and receiver’s name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used.
(iv) information stored on your Access Device, including if you allow the GMG Mobile App access to contact information from your address book, login information, photos, videos or other digital content, check ins (“Content Information”). The GMG Mobile App will periodically recollect this information in order to stay up-to-date;
(v) details of your use of or access to our Services including transaction details relating to your use of our Services, and the time, date and location of the place relating to any such transactions you may have entered into.
To the extent we associate Usage Information with your Personal Data we collect directly from you on the Services, we will treat such combined data as Personal Data.
c) Location information. We may use GPS technology and your IP address to determine your location (“Location Information”) – this may be used when the App is running in the foreground and the background of your Access Device. This is used to prevent fraud. For instance, if your Access Device says that you are based in the US but your card is being used to enter into an ATM Withdrawal or point of sale purchase in Spain, we may not allow that transaction to be processed. We treat this Location Information as Personal Data. Our card protection and fraud-prevention measures require this Personal Data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your Personal Data being used for this purpose.
d) Information we receive from other sources (Third Party Information). We work closely with third parties who provide, and from whom we collect, information about you including but not limited to information pertinent to our processes for verifying your identity, detecting and preventing fraud or illegal activity, and other such processes as required by applicable laws or regulations. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies. We may also work with contractors in technical or payment services, advertising networks, analytics providers, search information providers, customer service providers, software developers, and social media platforms such as Facebook, Twitter and/or Google).
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Certain features of our Services may use local stored objects (or flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. The Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit GMG, for example, to count users who have visited certain pages or opened an email, and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Services, as some features and services on our Services may not work properly. Depending on your Access Device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.
3. USES MADE OF THE INFORMATION
- We use information held about you in the following ways:
a) Personal Data: We will use this information:
(i) to carry out our obligations arising from your access to or use of the Services;
(ii) to provide you with the information, products and Services that you request from us;
(iii) to provide you with information about other goods and services we offer;
(iv) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;
(v) to protect against fraud, comply with laws and to confirm your eligibility to use our products and services;
(vi) to facilitate social interactions through our services and to make you aware if any of your contacts who are GMG Users and have location services enabled, are in the same area as you;
(vii) to administer and improve our Services, including troubleshooting, data analysis, security, testing, research, analytical, statistical and survey purposes;
(viii) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant promotional offers to you;
(ix) to comply with our legal and regulatory obligations, including responding to court orders and legal investigations and reporting to credit bureaus;
(x) to help us better understand your financial circumstances and behavior so that we may make decisions about how we manage your GMG Account; and
(xi) to process applications for products and Services available through us including making decisions about whether to agree to approve any applications.
3.2 We may associate any category of Personal Data with any other category of Personal Data and will treat the combined information as Personal Data in accordance with this policy for as long as it is combined.
4. THIRD PARTY TRACKING AND ONLINE ADVERTISING
4.1 Interest Based Advertising. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We may share, or we may permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our Website over time so that they may play or display ads on our Services, on other Access Devices you may use, and on other websites, apps or services, including on Facebook. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site and other information. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
4.2 Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, Google Plus, LinkedIn, Snapchat, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Service, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies. We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google Plus and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Service while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.
4.3 Cross-Access Device Linking. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third party partners who employ tracking technologies, or the application of statistical modelling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.
5.0 YOUR DATA COLLECTION CHOICES AND OPTIONS:
Cookies and Flash cookies. Most browsers allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Blocking or deleting cookies may negatively impact your experience using the Service, as some features and services on our Service may not work properly.
Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. To manage Flash cookie settings and preferences, you must use the settings manager on Adobe’s website or by clicking here. If you choose to delete Flash objects from our Service, then you may not be able to access and use all or part of the Service or benefit from the information and services offered.
Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s (NAI) online resources, at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance’s (DAA) resources at http://www.aboutads.info/choices.
Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
Mobile advertising. You may also be able to limit interest-based advertising through the settings on your Access Device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile App Choices app. Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again. You can stop all collection of information on you Access Device by uninstalling the GMG Mobile App.
Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or Access Device, login to your account on our Service, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
6. DISCLOSURE OF YOUR INFORMATION
6.1 We will disclose the data we collect from you to the following types of third parties for the following reasons:
a) to vendors, consultants, contractors, service providers, and other third parties we use to support our business or to support Services or information you request from us and that we provide to you;
b) advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others;
c) analytics and search engine providers that assist us in the improvement and optimization of our Site;
d) 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;
e) credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
f) in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets;
g) if GMG or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets;
h) to comply with any court order, law, regulation, or legal process, including to respond to any government or regulatory request;
i) in order to enforce or apply the Platform Terms, applicable Supplemental Terms, and/or any other agreements between you and us or to investigate potential breaches; or protect the rights, property or safety of GMG, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and regulatory compliance;
j) To our subsidiaries and affiliates;
k) With your consent or at your direction; or
l) For any other purpose disclosed by us when you provide the information.
7. DATA SECURITY AND RETENTION
7.1 Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.2 We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Services; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorized access.
We also follow policies to dispose of your records that are within our custody or control that contain Personal Data and non-public information about you when those records are no longer needed. We will dispose of those records by shredding them, erasing them or using techniques to make the information unreadable, unless otherwise required by applicable laws or regulations.
7.3 Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any Personal Data that you do not want to be seen, collected or used by other users, and that you have the right to disclose.
7.4 We store the Personal Data and information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal or other regulatory obligations.
8. CONTROL OVER YOUR INFORMATION
8.1 Email Communications. From time to time, we may send you emails regarding updates to our Site, products or Services, notices about our organization, or information about products or Services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain Website-related email communications (e.g., GMG Account verification, confirmations of transactions arising from the Services, technical or legal notices).
8.2 Modifying Account Information. If you have a GMG Account, you have the ability to modify certain information in your account (e.g., your contact information) by logging into and accessing the GMG Mobile App. If you have any questions about modifying or updating any information in your account, please contact us via email at: [email protected]
9. YOUR CALIFORNIA PRIVACY RIGHTS
9.1 California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]
10. LINKS TO THIRD-PARTY WEBSITES AND SERVICES
10.1 For your convenience, our Services may provide links to third-party websites or services that are not governed by this policy. To the extent that any linked third-party websites or services you visit are not owned or controlled by GMG, we are not responsible for those websites’ or services’ content or information practices. We encourage you to review the privacy policies of any website or service before providing any Personal Data.
11. TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES
GMG is based in the United States and we process and store information in the U.S. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your Personal Data receives an adequate level of protection in the jurisdictions in which we process it.