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Actualizadohace 3 años

Privacy Policy

1. General Provisions

This Privacy Policy sets out how GGC – Technology Company Limited (licence AA00623, registered office at 3 Kennedy Ave, office 314, Roseau, Dominica) (the "Service") collects, processes, stores and uses Personal Information provided by the User when accessing or using the website https://gogocard.me and its subdomains (the "Website") and any products or services offered by the Service (the "Services").

For the purposes of this Policy, "Personal Information" means any information relating to an identified or identifiable natural person, including, without limitation, name, address, email address, and financial and banking information. Aggregated and anonymised data that does not identify an individual does not constitute Personal Information.

This Privacy Policy shall be read in conjunction with the Cookie Policy.

The Service acts as a data controller within the meaning of Regulation (EU) 2016/679 (the "GDPR") and applicable European data protection law, where such law applies. The Website and the Services are not intended for use by United States Persons, and this Privacy Policy does not address or apply to any US federal or state privacy laws, including the California Consumer Privacy Act (CCPA) or the California Privacy Rights Act (CPRA).

This Policy sets out: the categories of Personal Information collected and the purposes of processing; the legal bases for processing; the categories of recipients to whom Personal Information may be disclosed; international transfers; the rights of the User; and the security and retention measures applied.

2. Personal Information Collected

The Service may collect and process the following categories of Personal Information:

  • Contact information — name, country of residence and email address;
  • Personal Cabinet information — username, authentication credentials and Personal Cabinet identifiers;
  • Financial information — Account balances, transaction history and applicable fees and commissions;
  • Identity verification data — an image of a government-issued identity document (passport, national identity card or driving licence), the issuing country and a selfie with a liveness check, as required under AML/KYC procedures;
  • Compliance-related information — information on the source of funds or financial background, where requested by the Service as part of enhanced due diligence.

The Service may also automatically collect technical and usage data when the User accesses the Website or the Services. Such data is generally aggregated, does not directly identify an individual and may include device and browser information, operating system, IP address and device identifiers; access times, pages viewed and referring URLs; and performance metrics. The Service may collect and process such data even where the User has not completed registration or onboarding.

Where the GDPR applies, the Service relies on the following legal bases:

  • Performance of a contract — for the provision of the Services under the Terms of Service;
  • Compliance with legal obligations — for compliance with AML/CFT, KYC, sanctions screening and record-keeping requirements;
  • Legitimate interests — for ensuring the security of the Services, preventing fraud and financial crime and improving the Services, balanced against the rights of the User;
  • Consent — for cookies and similar technologies and for marketing communications where consent is required (such consent may be withdrawn by the User at any time).

4. Purposes of Processing

The Service processes Personal Information for the following purposes: registration and verification of the User; provision and operation of the Services and processing of transactions; compliance with AML/CFT, KYC and sanctions obligations; detection, prevention and investigation of fraud and other unlawful activity; communication with the User regarding the Services; and compliance with the law and with lawful requests of competent authorities.

5. Disclosure of Personal Information

The Service may disclose Personal Information to the following categories of recipients, subject to appropriate confidentiality and data protection obligations:

  • the card issuer;
  • an identity verification (KYC) provider;
  • payment and deposit processing providers;
  • cloud hosting and IT infrastructure providers;
  • professional advisers (such as legal and audit advisers);
  • affiliated entities or entities under common control, subject to obligations no less protective than those set out in this Policy;
  • regulators, law enforcement and other authorities, where required by law.

For security reasons, the Service does not disclose the names of its individual service providers. Personal Information may also be disclosed: with the User's consent or upon the User's instruction; where necessary to protect the rights, property or security of the Service or its affiliates; for the detection, prevention or investigation of fraud, financial crime or unauthorised or unlawful activity; where required for the investigation of breaches of this Policy or of any agreement between the User and the Service; and where required by applicable law or regulatory obligations.

6. International Transfers of Personal Information

Personal Information may be stored and processed in data centres located in the various jurisdictions in which the Service or its providers operate. Any international transfer is carried out in accordance with applicable data protection law and is protected by appropriate technical and organisational safeguards.

7. Cookies and Similar Technologies

The Service uses cookies and similar technologies to improve the functionality of the Website and the user experience. Details are set out in the Cookie Policy.

8. External Websites

The Website may contain links to third-party websites ("External Websites"). The Service does not control and shall not be responsible for the content, policies or practices of External Websites. The User accesses External Websites at the User's own risk and is advised to review the applicable policies independently.

9. Rights of the User

Subject to applicable law and to the Service's AML/CFT and record-keeping obligations, the User may exercise the following rights:

  • the right to be informed about the processing of their Personal Information;
  • the right of access to their Personal Information;
  • the right to rectification of inaccurate or incomplete Personal Information;
  • the right to data portability, where applicable;
  • the right to object to processing;
  • the right to restriction of processing;
  • the right not to be subject to automated decision-making where such processing is not necessary for the performance of the contract;
  • the right to withdraw consent;
  • the right to erasure ("right to be forgotten"), where legally permissible.

Requests shall be submitted to legal@gogocard.me. The Service may request additional information to verify the User's identity before acting on a request. Where erasure of data or withdrawal of consent prevents the Service from fulfilling its legal or contractual obligations, the Service may be unable to continue providing the Services and may terminate the relationship accordingly.

10. Security of Personal Information

The Service applies appropriate technical and organisational measures to protect Personal Information, including encrypted data transmission using SSL/TLS; restricted access controls and multi-factor authentication; secure hosting environments; and confidentiality obligations imposed on authorised personnel. Security measures are reviewed periodically in light of technological and legal developments.

11. Retention of Personal Information

Personal Information is retained only for as long as necessary to fulfil the purposes set out in this Policy and to comply with applicable legal and regulatory obligations. In accordance with record-keeping requirements, certain Personal Information is retained for not less than 5 (five) years following termination of the relationship, or for a longer period where required by law or a competent authority.

12. Amendments to this Privacy Policy

The Service may amend or update this Privacy Policy at any time. Updated versions are published on the Website and take effect upon publication.