Privacy and Cookies

Moneygate Solutions Limited (registration number HE 406508, licensed by the Central Bank of Cyprus to operate as an Electronic Money Institution, license no 115.1.3.31/2020) (the 'Company') of Kafkasou 9, Treppides Tower, Floor 5, Aglantzia, 2112, Nicosia, Cyprus (www.moneygate.com) (the 'Website') collects certain data and information of persons visiting the Website and/or applying or availing for or making use of the Company's Services ('Services') through the Website.

By using the Company's Services through the Website, you (the 'Customer') have agreed with the Company's Privacy and Cookies Policy (the 'Policy'), which includes your consent for the collection and processing of certain data and information, which may include personal data of the Customer, in order for the Company to provide its Services to the Customer.

This Policy sets out the framework within which the Company collects, stores, processes, shares or otherwise uses the Customer's data and information.

Any defined terms in the Terms and Conditions of Use shall have the same meaning in this Policy.

The Company is the data controller of any personal data it collects from the Customer and will ensure that it complies at all times with the provisions of the General Data Protection Regulation (EU) 2016/679 (the 'GDPR'), as well as any applicable legislation and regulations in the Republic of Cyprus.

Any updates or amendments to this Policy will be posted on the Website.

The Company may collect and process the following data and information:

Technical Information: The type of browser and operating system you are using, the pages you visit on the Website, the amount of time you spend on the Website, the referring Website from which you come, the page you visit after leaving our Website, the types of fonts installed on your computer, your device's IP address, and your device's identifier.

Customer Details: In order to be able to register an account with the Company, you will have to provide the Company with certain details about yourself (the 'Customer Details'), which may include, without limitation, your name, gender, address, email address, date and place of birth, nationality, phone number, financial information, including your bank account details or card details used to make payments through your Moneygate account, as well as other personal data which is directly or indirectly connected to your details, including your photos, ID or passport documents, financial or bank statements, payslips and tax documentation, details on your occupation or employment.

Information about your activities: The Company may collect information about your activities when you visit and navigate through the Website. The Company may record information about the date, time and duration of your visit to the Website, as well as how you navigated from page to page, the specific content you viewed, your search queries and other activities while using the Website. The Company may also collect information about your activities as you use the Company's Services, for example the transactions you perform on your Moneygate account.

Additional Information: In addition to the Technical Information and the Customer Details, the Company may also collect, store and use additional information about the Customer for the purposes of customer satisfaction, business development, product development and improvement, marketing of its products and services, customer support and other purposes, which may include, for example, the way you use your Moneygate account, your financial behaviour, feedback you provide to the Company or in online fora, and other similar data and information which the Company may obtain from other websites and public databases.

Cookies: A 'Cookie' is a small file, typically of letters and numbers, downloaded on to a device when you access certain websites. Cookies are then sent back to the originating website on each subsequent visit. Cookies are useful because they allow a website to recognise a user's device. Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. For more information on our use of cookies, please refer to the Cookie Policy.

If you share information about yourself with the Company, the Company will collect, store and process such information for the purpose of delivering the Service to you, and in accordance with this Policy, the applicable legislation and any other legal requirements. This may include the transfer of your data to countries that have been deemed by the European Commission to provide an adequate level of protection for personal data and for other purposes such as the processing of payments through external payment providers, etc.

Processing of the Customer's personal data is carried out lawfully, on the following basis:

Contract: Processing your personal data may be necessary to perform a contract you have with the Company, including delivering the Services you have requested or taking steps before entering into a contract.

Legal obligation: Processing your personal data may be necessary for the Company to comply with the law or its regulatory obligations, including for example to satisfy our regulatory obligations for performing Anti Money Laundering and Know Your Client checks, for verifying the sources of your funds, for satisfying auditing requirements and to fulfil any requests from the court or other governmental authorities.

Legitimate interests: Processing your personal data may be necessary for the purposes of the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.

Consent: Your consent may be the basis for processing your personal data. In this case, you have the right to withdraw your consent at any time. For more information, please refer to the section 'Your Rights'.

Data Retention: The Company will retain your personal data for as long as required or permitted by law and regulation, for example to perform Anti Money Laundering checks or for auditing and other compliance purposes. If you request the deletion of your personal data, the Company will retain only the information that is necessary to fulfil any legal obligations and delete all other information.

Access to your Data: Access to the Customer's personal data is limited to the Company and to third parties with whom the Company may share such personal data for the purposes of delivering the Services to you, including, without limitation:

• our employees, officers, directors and professional advisors;
• the Company's banks and other financial institutions;
• IT service providers;
• auditors and legal advisors;
• governmental and regulatory authorities.

Sharing your Data: We may share your personal data with third parties, including for example government and regulatory authorities, law enforcement agencies and courts, where we are required to do so under applicable legislation or regulation, or where we consider such disclosure to be necessary for protecting our rights or property, or the rights or property of third parties, or for preventing fraud or illegal activity. We may also share your personal data with third parties who assist us in delivering our Services to you, or in running our business, or who provide services to us, or on our behalf.

Transfer of your data to third countries: We may transfer your personal data to countries outside the European Economic Area ('Third Countries'). In such cases, we will ensure that appropriate safeguards are in place to protect your personal data, in accordance with the GDPR. This may include entering into contracts with the recipients of your personal data in Third Countries, which contain standard data protection clauses approved by the European Commission, or transferring your personal data to Third Countries which have been deemed by the European Commission to provide an adequate level of protection for personal data.

Security of your data: The Company will use appropriate technical and organisational measures to ensure that your personal data is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, including firewalls, encryption and other security measures. Access to your personal data is restricted to those of our employees, officers, directors and professional advisors who need to access it for the purposes of delivering the Services to you.

Despite the above, 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 data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Under the GDPR, you have the following rights:

• The right to be informed: You have the right to be informed about the collection and use of your personal data.
• The right of access: You have the right to request access to the personal data we hold about you.
• The right to rectification: You have the right to request that inaccurate personal data we hold about you is corrected, and that incomplete personal data is completed.
• The right to erasure: You have the right to request that the personal data we hold about you is deleted. However, we may not always be able to delete your personal data, for example where we are legally required to retain it.
• The right to restrict processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, for example where you contest the accuracy of the personal data, or where you have objected to the processing.
• The right to data portability: You have the right to request that we transfer the personal data you have provided to us to another organisation, or to you, in a structured, commonly used and machine-readable format.
• The right to object: You have the right to object to the processing of your personal data in certain circumstances, including where we process your personal data for direct marketing purposes.
• Rights in relation to automated decision making and profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

If you wish to exercise any of the rights set out above, or to withdraw your consent, please contact us at info@moneygate.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You have the right to make a complaint at any time to the relevant data protection authority (in Cyprus, the Office of the Commissioner for Personal Data Protection). We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority so please contact us in the first instance.

When you enter our Website for the first time and where we wish to issue your computer with a cookie, you will be asked to consent to such use.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

The Company uses the following types of cookies on the Website:

Strictly necessary cookies: These cookies are essential to enable you to move around the Website and use its features, such as accessing secure areas of the Website.

Performance cookies: These cookies collect information about how visitors use the Website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.

Functionality cookies: These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Targeting cookies or advertising cookies: These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the Website operator's permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

• Necessary cookies: These cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Website will not then work.
• Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our Website, and will not be able to monitor its performance.
• Functional cookies: These cookies enable the Website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
• Targeting cookies: These cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Advertising measurement (Meta): where you accept cookies on this Website, we load the Meta pixel provided by Meta Platforms Ireland Limited. It reports to Meta the pages you view on this Website and when you successfully submit an enquiry form, together with the technical identifiers Meta sets in your browser. We use this only to measure and improve our advertising on Facebook and Instagram. We do not send Meta your name, email address, telephone number or any other detail you type into our forms. No Meta pixel is loaded and no data is sent to Meta unless and until you accept cookies.

You can withdraw your consent at any time by selecting 'Cookie settings' at the foot of any page of this Website and choosing to decline. Reporting to Meta stops immediately for the rest of your visit and on later visits; you may also delete the cookies already set through your browser settings.

If you do not want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set. However, if you do this, you may not be able to access all or parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Website.

If you have any questions about this Policy, please contact us by email at info@moneygate.com.