PRIVACY NOTICE

Last revised: 14.03.2023

This is the Privacy Notice of GlobiancePay PTE. LTD. limited by shares (hereinafter – “Company”, “we’, “us “,”our”). This document together with our [Terms of Use](indicate the terms of use link) sets out the basis on which any personal data we collect from you, or that you provide to us as a user of our services, will be processed by us for provision of our services to you through our website and/or other applicable software. The website can be accessed via the following link: [www.globiancepay.io](www.globiancepay.io) (hereinafter – the “Website”). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our Website, you are accepting and consenting to the practices described in this Privacy Notice.

We take the protection of our user’s (“user/you/your”) personal data very seriously and strictly comply with applicable data protection laws and regulations. In this Privacy Notice below we provide you with an overview of what data we collect for what purpose and how we ensure the protection of such data.
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1) Purpose and Legal Basis of Processing Data; Legitimate Interests

1.1. Legal basis for collection and processing of your personal data.

We will only collect, use and/or pass on Personal Data if this is permitted by law or if the user consents to the data processing. Applicable legal provisions are in particular those of the regulation the General Data Protection Regulation (EU) 2016/679, the Data Protection Act, the Data Protection Regulations. We will only collect, use and/or pass on Personal Data if this is permitted by law or if the user consents to the data processing.

1.2. Your data will be used for the following purposes:

- To implement this Privacy Notice and carry out the contractual relationships between you and us regarding our services available via the Website and/or our other software;
- To contact you in any matters regarding our services (also using emails and messaging), and to ensure the technical functionality of our services and fulfillment of contractual or pre-contractual obligations;
- To prevent fraudulent behavior by any of our users;
- To analyze your use of our services and improve our services;
- With your express consent or instruction to carry out our business activities or send you newsletters and other advertising materials;
- To follow our internal policies and protect our legitimate interests;
- To save your blockchain data (e.g. your wallet address) on the distributed ledger;
- To comply with our legal obligations before third parties involved in the process of provision of our services;
- To provide you with information about other goods and/or services we offer that are similar to those that you have already purchased or enquired about;
- To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. You have the right to request we not process your data for direct marketing;
- To notify you about changes to our services;
- To ensure that content from our Website is presented most effectively for you and your device;
- For other purposes otherwise explained in this Privacy Notice or by any further communication from us;
- To comply with any applicable ‘know your customer’, anti-money laundering, or anti-terrorist financing laws and regulations in any jurisdiction in which we operate.

2. Your Consent

We can collect and process your data with your consent. By clicking the “I Agree” button on any of our resources or using our Website, or other of our services you confirm that you fully agree with this Privacy Notice and provide explicit and full consent to us for the collection, processing, and transferring of your data.

3. Recipient(s) of Your Data

We, as well as our external service providers, receive your data for the provision of our services. We may need to share your information with our external service providers, affiliates, and/or agents. We require that third-party organizations who handle or obtain personal information as service providers acknowledge its confidentiality and undertake to respect an individual’s right to privacy and comply with data protection principles including this Privacy Notice.

Information We May Collect From You

4.1. We may collect and process the following data about you:

- Your name;
- Physical address;
- E-mail address and phone number;
- Credit card information, XDC wallet address, and other financial information applicable for the provision of our services;
- Date of birth;
- Gender and nationality.
To obtain the above-mentioned information we may either ask you during your filling of any forms (e.g. registration forms) to access our services. Or, we may ask you to provide us with copies of respective documents by phone, e-mail, or otherwise. Such documents include but are not limited to:
- Passport;
- Driver’s license;
- Transaction history;
- Certificates.

4.2. Company may also gather data about you:

- When you engage with us on social media;
- When you enter prize draws or competitions;
- When you book any kind of appointment with us or book to attend an event;
- When you choose to complete any surveys we send you;
- When you comment on or review our products and services;
- When you’ve given a third-party permission to share with us the information they hold about you;
- When Company suppliers and partners share information with us.

4.3. We may collect your data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law in relation to KYC and AML regulations.

4.4. We may collect notes from our conversations with you, details of any complaints or comments you make, details of investments you made, and how and when you contact us.

4.5. Concerning each of your visits to our Website we may automatically collect the following information:

- Technical information, including the internet protocol (IP) address, used to connect your computer to the internet;
- Browser type and version;
- Time zone setting;
- Browser plug-in types and versions;
- Operating system and platform;
- Information about your visit, including the full uniform resource locators (URL) clickstream to, through, and from our Website (including date and time);
- Products you viewed or searched for;
- Page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs);
- Methods used to browse away from the page and any phone number used to call our customer service number.

4.6. Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) and may receive information about you