This policy together with the General Terms of Service apply to your use of:
a) The web-sites of SnapSwap International S.A.: www.snapswap.eu and www.gloneta.com (the "Sites")
b) The Gloneta Money Messenger App ("Gloneta App") once you have downloaded a copy of the App onto your mobile telephone or handheld device ("Device"); and
c) any of the services accessible through the App or the Site (the "Services").
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 used by us.
SnapSwap International S.A. is the data controller responsible for your personal data.
We have appointed a data protection officer ("DPO"). Our DPO has a number of important responsibilities including:
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us or our DPO via support channels (email@example.com or firstname.lastname@example.org).
You have the right to make a complaint at any time to The the EU’s independent data protection authority (“EDPS”) www.edps.europa.eu. We would, however, appreciate the chance to deal with your concerns before you approach the EDPS so please contact us in the first instance.
We will always keep your data safe and private, never sell your data, allow you to manage and review your marketing choices at any time.
We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.
We also use Local Shared Objects, commonly referred to as "Flash cookies", to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud and to support our sites and services.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our website. The help section of most browsers or browser add-ons provides instructions on blocking, deleting or disabling cookies.
We will collect and process the following data about you:
Below is a summary of data that we make use as part of our Services.
We use information held about you in the following ways:
We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws.
We send personal data to the following sets of data processors in order to perform the Services:
We may also disclose your personal information in the following circumstances:
◦ enforce or apply the General Terms of Service and/or any other agreements between you and us or to investigate potential breaches; or
◦ protect the rights, property or safety of SnapSwap, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7.2 Third party service partners
From time-to-time, we may partner with certain third parties in order to offer you co-branded services or promotional offers. In order to provide these services to you and to allow us and any associated third party to optimise their/our offering to you, we will share some of your personal data with such third parties. We will obtain your express opt-in consent before we share your personal data with any third party company.
You can withdraw your consent at any time after giving your explicit opt-in consent by contacting support via email.
8. Storage security and cross-border transfers
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be securely encrypted and stored. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App and/or our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 data transmitted to our App or our Sites; 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.
9. Retaining your information
10. Marketing and Communications
10.1 Promotional offers from us
We may use your personal data (such as your Submitted Information or Location Information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have signed up to and/or utilise the Services and, in each case, you have not declined receiving marketing notifications.
We will obtain your opinion before we share your personal data with any third party company for marketing or promotional purposes.
We may use your Personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by notifying us via email.
11. Your legal rights
You have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team email.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our support team via email.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. As an e-money institution, SnapSwap is under certain obligations to retain certain data for a minimum of 6 years (see above). Please note that these retention requirements supersede any right to erasure requests under applicable data protection laws.
Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. As an e-money institution, SnapSwap is under certain obligations to process and retain certain data for compliance purposes. Please note that these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data then we may not be able to provide the Services and it is likely we will have to terminate your account.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the Services). In this case, we may have to cancel your use of the Services but we will notify you if this is the case at the time.
Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support team via email.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
13. What we may need from you
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.
14. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
15. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the Services). In this case, we may have to cancel your use of the Services but we will notify you if this is the case at the time.