We at Gold Pomelo (“GP”) respect your privacy and are committed to protecting your
personal data. This Privacy Policy (“Policy”) will explain how we collect, use, and process
the information we collect from you when you use any of our payment services.
Who/what does this Policy apply to?
This Policy applies to all users all around the world using our products, services, technologies, features, collectively referred to as “Services”, as well as anyone visiting our website or other platforms.
By submitting information to us, or using our products, services, technologies, or features, you acknowledge that you have read and agree to the collection, use, disclosure, and processing of your personal data (or the personal data of any individual you provide) as outlined in this Policy.
Data Controller
“We”, “us”, “our” and “GP” used in this Policy refer to the GP group company that serves as the Data Controller for your information/data. The specific Data Controller responsible for your information under this Policy depends on your country of residence and/or the entity that engages us to receive Services. You may contact our privacy team at [email protected]
What types of information do we collect and why?
When you create an account with us to use our Services, we need certain information (not exhaustive) such as name, address, government-issued ID, tax ID, contact details, email address, and business information for identification and verification purposes for our KYC/AML due diligence process for us to comply with our legal obligations. We may collect and process transaction-related information (not exhaustive) such as payment details. We do not collect and process any personal information of children below 18 years of age.
Different types of personal information we may collect from you and how we process them:
Information you provide us:
When you create an account to use our Services, you will have to provide certain personal information to us for security, identification and verification purposes. Additional information may include payment reason, geographic location, photograph, proof of address, proof of residency. Information required is not exhaustive in relation to our due diligence process.
The content of your communications with us, which we collect through emails, recorded phone calls, online chats, recorded online meetings, direct messages, and other methods.
Information collected through feedback and promotions voluntarily provided by you and not compulsory. Such information may be collected when you provide feedback to us about our Services, and/or when you participate in promotions. These collected information from you through feedback and promotions may be processed with our satisfactory discretion or when applicable, with your consent.
Information collected from you automatically from the use of our Services
We may collect information automatically when you use our Services or visit our website to prevent fraud, misuse, or to understand your use and to improve our Services. This may include but is not limited to the full Uniform Resource Locators (URL) clickstream to, through and from our website, Services your viewed, page interaction information, duration of visits to specific pages.
Information we may collect include but is not limited to; transaction information (e.g., payments processed through our Services), identification information (e.g., name, email address, contact information, internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone), payment details (e.g. credit card information, bank account details)
Information collected from third parties or sources
We may collect information about you from other sources or third parties which may include but is not limited to the payment service providers you use to transfer money to us which will be providing us with your personal information, business associates, service providers, credit bureaus, advertising networks, analytics providers, other providers of credit information, financial institutions, companies and other official registers and databases, or other public information. We may check the information you have provided us against governmental or private identity record databases, with fraud prevention agencies or with credit reference agencies to verify your identity.
How will we use your personal information?
We will only process your personal information where permitted by law, based on several legal grounds depending on your location. This includes instances where you have provided consent for us to process your information, with local regulations applying when consent is the basis for processing. We may also process your information if it is necessary for our legitimate interests (or those of a third party), provided that your rights and interests do not override those interests. Additionally, we may process your personal data to comply with legal obligations, such as laws, regulations, court orders, or to fulfil contractual obligations to you. We may also process your personal information to communicate with you regarding your account and our Services. Lastly, we may process your information when necessary to protect your vital interests or the interests of others.
Who do we share your personal information with, and why?
Due to our global business, we may transfer, share and process your personal information in countries outside of your country of incorporation, business operations, or residence where our business associates, payment partners, financial institutions, and any service providers or subcontractors we engage to perform any obligation(s) in the contract we enter either with them or with you, are located, with strict confidentiality. These countries may have different data protection regulations. In certain circumstances, we may also be required to disclose your personal data to local law enforcement or government authorities in response to lawful requests.
Additionally, we may share your personal information with advertisers and advertising networks to display relevant ads, as well as analytics and search engine providers to help improve and optimize our site. In the event of a business sale or merger, your personal data may be disclosed to potential buyers, investors, or merger partners.
Your personal information may also be sent to payment beneficiaries when you initiate a payment. We may also share your personal information to comply with legal obligations, enforce agreements, protect the rights and safety of our business, customers, or others, prevent and detect fraud or crime, and respond to legal requests such as subpoenas or court orders. Additionally, your personal information may be used to assess financial risks, recover debts, develop customer relationships, or if you consent, to share details when using our services.
You may request the list of who we have shared your personal information with by request with our privacy team at [email protected]
Data retention and protection of your personal information
Your personal information will be retained for as long as necessary to comply with applicable laws and regulations, fulfil any ongoing obligations to you, and for our business purposes where consistent with any legal requirements. Even after you close your account or request deletion of your personal data, we may still retain certain information in cases such as processing pending transactions, complying with anti-money laundering laws, detecting fraud, fulfilling legal obligations, resolving disputes, enforcing agreements, or for regulatory reporting purposes.
Retention periods are based on various factors including legal obligations, relevant guidelines, business interests, and our contractual obligations with you. Depending on these factors, your data may be stored for the duration you engage our Services and at least 7 years thereafter or as required per the applicable laws and regulations. Once the retention period expires, your data will be securely deleted or anonymized.
We respect your privacy and take all necessary steps to ensure your data is protected. Access to your information is limited to authorized personnel bound by confidentiality agreements. Your data is stored in secure infrastructures with appropriate safeguards against accidental loss or destruction, though we cannot guarantee complete security for data transmitted over the internet. We regularly evaluate our security measures to uphold the highest standards of data protection and will report any breaches in accordance with applicable laws.
Your rights
Laws in your jurisdiction may grant you certain rights regarding the personal information we hold about you. If you have any questions about how we handle your data, you can contact us at [email protected]
Exercising these rights might be subject to certain exemptions, such as to protect public interest, maintain legal privilege, or where the rights of other individuals are involved.
We may need to retain specific information for record-keeping purposes or to comply with legal obligations, such as anti-money laundering requirements, even after you request data deletion or close your account. This also includes completing any transactions that were initiated before your request.
Generally, there is no fee for accessing your personal data or exercising other rights, but we may charge a reasonable fee or refuse requests if they are groundless, recurring, or excessive. To ensure the security of your data, we might request additional information to confirm your identity before fulfilling any data-related requests.
If you no longer wish to receive marketing emails, you can opt-out by following the instructions in the email. We will process your request promptly, but please note that you will still receive essential administrative messages.
You have the right to:
Request a copy of the personal information we hold and verify its lawful processing in a digital/machine readable format.
Request corrections to inaccurate personal information about you and to suspend processing in this situation while the information is being verified.
Request deletion of personal information when we have no valid reason to continue processing it, or when the data has been unlawfully processed.
Withdraw consent for data processing, without affecting the lawfulness of prior processing.
Object to direct marketing.
Changes to this Policy
We reserve the right to make changes to this Policy from time to time. To the extent allowed by applicable law, if you continue using our services after receiving notice of any updates or changes to this Policy, it will indicate your acceptance of the revised terms. Should you disagree with any of the modifications, you can deactivate your account and/or Services with us at any time.
Contact
If you have any questions, requests, or feedback regarding this Policy, you may contact our privacy team at [email protected]
