We collect Personal Data about you when you visit our Sites or use our Services, including the following:
Registration and use information – When you register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfil the Services you request. Depending on the Services you choose, we may require you to provide us with personal information and contact details from you, such as but not limited to name, date of birth, nationality, place of birth, your photographs, address, telephone number, email address and bank account details. If you are a corporate entity, we may also collect your registered name, registered office address, memorandum of association, articles of association, list of current shareholders, list of current directors, annual return, identification and proof of address of beneficial owners, directors and any power of attorney. We may require you to provide us with additional Personal Data as you use our Services.
Transaction and experience information – When you use our Services or access our Sites, for example, to make purchases from merchants, to receive money, to process payments, or to send money to friends and family, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information.
Participant Personal Data – When you use our Services or access our Sites, we collect Personal Data you provide us about the other participants associated with the transaction.
Send or request money: When you send or request money through the Services, we collect Personal Data such as name, postal address, telephone number, and financial account information about the participant who is receiving money from you or sending money to you. The extent of Personal Data required about a participant may vary depending on the Services you are using to send or request money.
Pay or request someone else to pay a bill: If you use our Services to pay a bill for the benefit of someone else, or if you request a User to pay a bill for you, we collect Personal Data from you about the account holder such as name, postal address, telephone number, email address, and account number of the bill that you intend to pay or request to be paid.
Add value to your accounts: If you use our Services to add value to your Account or any other account you may have, or if you ask a User to add value to any of these accounts, we may collect Personal Data from you about the other party, or from the other party about you to facilitate the request.
Personal Data about your friends and contacts – It may be easier for us to help you transact with your friends and contacts if you provide Personal Data such as name, email address and telephone number about your friends and contacts while using a Service or if you connect your contact list or friend list to your Account. If you choose to connect your contact list information on your device with your Account and/or establish an account connection between a social media platform and your Account, we will collect and use your contact list or friend list information to improve your experience when you use the Services.
Personal Data about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.
Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us and contact our customer support teams
We may Process your Personal Data for a variety of reasons to operate the Sites and provide the Services, including to:
To manage our business needs, such as monitoring, analysing, and improving the Services and the Sites’ performance and functionality. For example, we analyse User behaviour and perform research about the way you use our Services.
To manage risk and protect the Site, the Services and you from fraud by verifying your identity, and helping to detect and prevent fraud and abuse of the Site or Services.
To fulfil any contractual obligations, we have with you; including to comply with all applicable laws and regulations.
With your consent, including to:
You can withdraw your consent at any time and free of charge. Please refer to the below section “7. Your Rights and Privacy Choices” for more information on how to do that.
We share Personal Data with our employees that perform services and functions at our direction and on our behalf such as services to verify your identity, assist in processing transactions, send you advertisements for our products and services or provide customer support.
We may share personal data with third party companies and organisations contracted by us to help supply, maintain or facilitate our site or our services. These third parties may include (without limitation) IT support teams, banks, exchange facilities having control or jurisdiction over us and electronic search providers carrying out anti-money laundering and sanction checks for us.
With other financial institutions that we have partnered with to jointly create and offer a product or service: We may share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product. These financial institutions may only use this information to offer Weezzo-related products, unless you have given consent for other uses.
With the other parties to transactions when you use the Services, such as other Users, merchants, and their service providers: We may share information with the other participants to your transactions, including other Users you are sending or receiving funds from, and merchants or their service providers when you use the Services to pay for goods or services. The information includes:
With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for Weezzo’s business purposes or as permitted or required by law, including:
Disclose necessary information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
With your consent:
We also will share your Personal Data and other information with your consent or direction, including if you authorise an account connection with a third-party account or platform.
In addition, Weezzo may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Site and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent.
Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorising an account connection, you should review the privacy notice of any third-party that you authorised to have an account connection that will gain access to your Personal Data as part of the account connection. For example, Personal Data that Weezzo shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.
Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers.
If you make transactions with parties or connect our Service with platforms, such as social media, outside the EEA or Cyprus, we are required to transfer your Personal Data with those parties in order to provide the requested Service to you.
Choices Relating to the Personal Data We Collect
Personal Data. You may decline to provide Personal Data when it is requested by Weezzo, but certain Services or all of the Services may be unavailable to you.
Location and other device-level information. The device you use to access the Site or Services may collect information about you, including Geolocation Information and User usage data that Weezzo may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
If you have an Account, you generally may review and edit Personal Data by logging in and updating the information directly or by contacting us. Contact us if you do not have an Account or if you have questions about your Account information or other Personal Data.
Choices Relating to Communication
We will send communications to you that are required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.
Rights to Access:
You have the right to request copies of your personal data.
Information must be provided without delay and at the latest within one month of receipt. WEEZZO will be able to extend the period by a further two months where requests are complex or numerous. If this is the case, WEEZZO will inform the individual within one month of the receipt of the request and explain why the extension is necessary.
Can we charge a fee for dealing with a subject access request?
WEEZZO will provide a copy of the information free of charge. However, WEEZZO can charge a “reasonable fee” when a request is manifestly unfounded or excessive, particularly if it is repetitive.
The fee if applied will be based on the administrative cost of providing the information.
If at any time, WEEZZO refuse to respond to a request, we will explain why to the individual, informing them of their right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within one month.
When information is provided:
WEEZZO will verify the identity of the person making the request, using reasonable means.
Right for rectification;
When should personal data be rectified?
Individuals are entitled to have personal data rectified if it is inaccurate or incomplete.
If WEEZZO have disclosed the personal data in question to others, we will contact each recipient and inform them of the rectification – unless this proves impossible or involves disproportionate effort. If asked to, WEEZZO will also inform the individuals about these recipients.
How long does WEEZZO have to comply with a request for rectification?
WEEZZO must respond within one month.
This can be extended by two months where the request for rectification is complex.
Where WEEZZO is not taking action in response to a request for rectification, we will explain why to the individual, informing them of their right to complain to the supervisory authority and to a judicial remedy as required to do so by the General Data Protection Regulation (GDPR).
Your right to erasure.
When does the right to erasure apply?
The right to erasure does not provide an absolute ‘right to be forgotten’. Individuals have a right to have personal data erased and to prevent processing in specific circumstances:
WEEZZO has a legal obligation to obtain data on you meeting with any legal obligations, based on the legal obligations imposed on WEEZZO, individuals may have no right to erasure, no right to data portability or right to object on the information gathered meeting with WEEZZO’s legal obligation depending on the service taken.
When can WEEZZO refuse to comply with a request for erasure?
WEEZZO can refuse to comply with a request for erasure where the personal data is processed for the following reasons:
to comply with a legal obligation for the performance of a public interest task or exercise of official authority.
the exercise or defence of legal claims.
Does WEEZZO have to tell other organisations about the erasure of personal data?
If we have disclosed the personal data in question to others, we must contact each recipient and inform them of the erasure of the personal data – unless this proves impossible or involves disproportionate effort. If asked to, WEEZZO must also inform the individuals about these recipients.
Your right to restrict processing;
When does the right to restrict processing apply?
WEEZZO will be required to restrict the processing of personal data in the following circumstances:
WEEZZO may need to review procedures to ensure we are able to determine where we may be required to restrict the processing of personal data.
If WEEZZO have disclosed the personal data in question to others, WEEZZO must contact each recipient and inform them of the restriction on the processing of the personal data – unless this proves impossible or involves disproportionate effort. If asked to, WEEZZO must also inform the individuals about these recipients.
WEEZZO must inform individuals when we decide to lift a restriction on processing.
Your right to data portability:
The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services.
It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
It enables consumers to take advantage of applications and services which can use this data to find them a better deal or help them understand their spending habits.
WEEZZO will respond without undue delay, and within one month. This can be extended by two months where the request is complex or where WEEZZO may receive a number of requests. WEEZZO will inform the individual within one month of the receipt of request and explain why the extension is necessary, if applicable.
Where WEEZZO are not taking action in response to a request, WEEZZO will explain why to the individual, informing them of their right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within one month.
Right to object:
Individuals have the right to object to:
WEEZZO will stop processing the personal data unless:
WEEZZO can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
the processing is for the establishment, exercise or defence of legal claims.
We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres (located in the EU), and information access authorisation controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorised.
The Site and Services are not directed to children under the age of 18.. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of majority, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of majority.
If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Users of the change using email or other means.
You are entitled to have access to your personal data. You may request by writing to us (at the address given below), details of your information which we hold and the purposes for which it is held. We will provide this information within a month of your request. Where requests are complex or numerous Weezzo will be able to extend this period by a further two months, should this be the case Weezzo will inform you within one month of the receipt of your request and explain why the extension is necessary. Should your request be unfounded, excessive or repetitive you may be charged a reasonable fee
Our Data Protection Officer can be contacted by email firstname.lastname@example.org or in writing at Weezzo LTD, 84 Spyrou Kyprianou, 4004 Limassol, Cyprus.
If you are not satisfied by the way in which we address your concerns, you have the right to lodge a complaint with the Supervisory Authority for data protection.
Cyprus Data Protection Commissioner;
Office of the Commissioner for Personal Data Protection
1 Iasonos str., 1082 Nicosia
P.O.Box 23378, 1682 Nicosia
Tel: +357 22818456
Fax: +357 22304565