Some of the pages on Pocket Money’s website may contain links to third parties’ websites. Those sites are governed by their own terms of confidentiality, and Pocket Money shall not be responsible for their operations, including without limitation their principles of use of data. The users providing information on such third parties’ websites or through those shall read the terms of confidentiality of such websites before providing those with their personal information.
Children shall not have the right to use the Services of Pocket Money and we ask minors (individuals under 18 years old) to not provide us with any personal information and not use the Services of Pocket Money.
2. Information We Collect
The necessary information: In order to create an account in Pocket Money or use the Services of Pocket Money you shall provide the following:
· Contact information (such as your name, email, address, phone number and country of residence) which is provided by you by filling out the forms on the Website, on the phone;
· The information allowing us to offer you the Services of Pocket Money, which could include the information related to your bank accounts, credit card, debit card, detailed data allowing us to prevent or detect activity related to money laundering and financing of terrorism, copies of your valid identity document with your photograph in a state-approved format and/or similar identification and clarification data which we regularly request in our sole discretion, and information about you from the credit reference bureau for confirmation of your identity in compliance to the applicable “Know Your Client” rules;
· Information you provide us with or permit us to receive via third party service providers. In order to protect all our clients and partners from potential fraud, we check the information provided by you with third parties. During such checking we receive your personal identity information. In particular, if you register a credit or a debit card or a bank account in Pocket Money, we will use the procedure of card authorization and fraud detection with the purpose of checking that your bank data or card data and address match the information you provided Pocket Money with, and that the card hasn’t been reported lost or stolen. We may as well collect the information on you from other sources, including other companies (subject to their privacy policies and applicable law) and from other accounts which we may have reason to believe you hold (partly or solely);
· Detailed information on any operations you carry out with help of the Services of Pocket Money. Such information includes the amount and the type of the operation, the email address or the phone number of the third party. In addition, when you send funds to another Pocket Money’s client you may be requested to provide the personal information to that client in order to complete the transaction. Those detailed data may as well be provided to us by that client. We do as well need the Internet-address (IP-address) and other identification information on the computer or device you use to access your Pocket Money account or to use the Services of Pocket Money, in order to receive assistance in detection of possible cases of unauthorized deals;
· Information on your computer, such as your IP-address, browser type, visited pages or leaving those, and the operating system;
· Information provided via your mobile devices, such as your location, phone ID, username, contact information;
· Information about communication with us. For example, when you requested our support, sent us requests, questions or comments or reported a problem to us, by email, online or in any other manner, we save such information and our responses to you in your account’s history;
· Information which you provide through the website, including such in the form of comments, participation in discussions;
- Demographic information;
- Geo-location information;
- Data extraction and formation of a financial profile.
In case we are unable to verify the information you provide, we may ask you to upload additional information (for example, your driving license, credit card statement, and/or your latest utility bill or other information connecting you to the relevant address) or answer additional questions in the online mode to assist the your data verification.
When a registered user of the Services of Pocket Money attempts to engage an individual who is not a registered user of the Services of Pocket Money into a deal (for example, sending a payment or another transaction to an individual or requesting a payment from such), we will save the data which the registered user of the Services of Pocket Money provides us with, including, for example, the email address, phone number and/or name of the other party. Despite that certain information is stored during a definite period of time in accordance with the applicable law, we may use it to promote our products to unregistered users. In addition, such entities have the same rights to access and correct their personal information (admitting their data were correct) as anyone else using the Services of Pocket Money.
3.How we use the collected information
Our primary purpose in collecting, storing and processing your personal information is to provide you with a secure, seamless, efficient, and customized experience. You expressly agree that we may use your personal information for:
· Processing operations and provision of the Services of Pocket Money;
· Verification of your identity, including account creation or password changing;
· Resolution of disputes, collection of fees and troubleshooting of problems;
·Risk management, or for detection, prevention and/or remediation of fraud or other potentially illegal or prohibited activities;
·Detection, prevention or remediation of violations of the Policy or effective user agreements;
· Provision of customer support services;
·Improvement of the Services of Pocket Money by customizing your user experience;
·Measurement of the efficiency of the Services of Pocket Money and improvement of their content and structure;
· Management and protection of our information technology infrastructure;
·Performance of creditworthiness and solvency verification, comparing of information accuracy and verifying of it with third parties
We communicate with our users on the regular basis by means of the Services of Pocket Money for provision of requested services, in order to:
·Resolve clients’ claims or complaints made by users via the Services of Pocket Money;
·Respond to client service requests;
·Inform the users of, as we believe, illegal use of their accounts or any other operations;
·Verify the information related to the users’ identity, actions or activities in your account.
· Perform collection;
· Check suspicious operations.
We use the email, phone number, as well as any services connected thereto, Internet-messengers or address for your confirmation of creation of an account in Pocket Money, for sending notifications of the payments you send or receive via Pocket Money (including the referral payments described below). We may as well send you information about important changes to our products and services, and send notifications and other information subject to disclosure, required by law. In general, the users can not avoid such messages, but those will be of, primarily, informational, rather than commercial nature.
In connection with independent audits of our financial reports and operations, auditors may request to, as an example, contact our clients in order to confirm our records are precise. However, such auditors may not use personal information for other purposes.
We may unite your information with the information received from other companies and use it to improve and customize the Services of Pocket Money.
4. How we share information
We do at times engage third parties and their affiliated entities, agents and subcontractors (Service Providers) in provision of certain technological or administrative services in connection with the Services of Pocket Money. For example, a Service Provider may be requested to perform as operation processor, provide credit reports or estimations, verify clients’ identity, detect suspicious operations, provide services of ensuring safety and manage operations or perform audit thereof.
In some cases, a Service Provider will perform collection of your personal information from other sources on our behalf. We may as well use a Service Provide as a host of one or more of Websites or commission them to carry out administration thereof, process and store information and perform similar functions related to the technology on our behalf. In such conditions, your personal information which a Service Provider receives is limited by solely the data required for the provision of the service to us.
In certain cases, we may as well share some personal information collected by us with carefully selected business partners which shall be obliged to, at first, sign an agreement binding them to keep confidentiality and security of the information and prohibiting them to use it for unapproved purposes. We may disclose personal information without notifying you in case we are permitted or required to do so in accordance with a law, standard, search warrant, summons, decree of the court or notification of the effective standards. We may as well disclose personal information without notice for prevention of fraud or abuse, or for protection of rights, property or safety of Pocket Money itself, its clients, employees, service providers or the community.
Pocket Money will consider all the available information related to a client confidential when such information is not the public domain. Subject to this term, Pocket Money will not disclose such confidential information to third parties.
We may provide your personal information to the companies which provide services required to support us in our commercial activities, for example, distribution of informational letters by email, or offering client services. Such companies are authorized to use your personal data only in terms of necessity of provision of such services to us.
We may provide summarized, non-personal identification data publicly and to our partners, for example, publishers, advertisers or partnering websites. For example, we may publicly disclose the data reflecting trends or publish a market research. Please note that third parties which you purchase from and sign a contract with have their own privacy policies, and Pocket Money shall not be responsible for their operations, including without limitation their principles of working with information. If you create an account in Pocket Money directly on a website of a third party or via an application of a third party, any data you specify on such a website or in such an application (and not directly via the Services of Pocket Money) will be provided to the owner of such a website or an application of a third party, and your data may be governed by their privacy policies.