Privacy Policy

QMoney has developed this Privacy Policy, in accordance with the requirements set out in the EU 2016/679 General Data Protection Regulation, to explain how we may collect, retain, process, share and transfer your Personal Data when you visit our Site or use our Services. This Privacy Policy applies to your Personal Data when you visit our Site or use our Services, and does not apply to online websites or services that we do not own or control, including websites or services of other QMoney Users.

This Privacy Policy is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Sites and Services. Please note that our Service offerings may vary by region. This Privacy Policy may be supplemented with additional notices depending on the Sites and Services concerned. Supplementary information can be found in the Cookie Policy

Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Policy.

1. What Information Do We Collect and Why?

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 retain Personal Data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal data in accordance with this Privacy Policy.

The cookies we use have defined expiration times; unless you visit our Sites or use our Services within that time, the cookies are automatically disabled and retained data is deleted. Please consult our Cookie Policy for more information.

2. How Do We Process Your Information?

We may Process your Personal Data for a variety of reasons to operate the Sites and provide the Services, including to:

• initiate a payment, send or request money, add value to an account, or pay a bill
• authenticate your access to an Account
• communicate with you about your Account, the Site, the Services, or QMoney
• create an account connection between your Account and a third-party account or platform
• perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes

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:

• To market to you by delivering marketing materials about QMoney products and online Services. We may also Process your Personal Data to tailor certain Services or Site experiences to better match our understanding of your interests.
• To provide personalised Services offered by QMoney on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature or offer to you on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as advertising or analytics companies to provide these online services.
• To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the Sites and Services and provide you with location-based Services, such as search results, and other personalised content.
• To make it easier for you to find and connect with others, we may use your information you have shared with the Service to suggest connections between you and people you may know. For example, we may associate information that we learn about you through your and your contacts’ use of the Services, and information you and others provide to suggest people you may know or may want to transact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service.
• To respond to your requests, for example to contact you about a question you submitted to our customer service team.

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.

3. Do We Share Your Personal Data?

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy. We may share your Personal Data or other information for the following reasons:

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 QMoney-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:

• Personal Data necessary to facilitate the transaction;
• Personal Data to help other participant(s) resolve disputes and detect and prevent fraud; and
• Anonymous data and performance analytics to help merchants better understand the uses of our Services and to help merchants enhance Users’ experiences.

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 QMoney’s business purposes or as permitted or required by law, including:

• if we need to do so to comply with a law, legal process or regulations;
• to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to QMoney;
• if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
• to protect the vital interests of a person;
• with credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes;
• to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
• to protect our property, Services and legal rights;
• to facilitate a purchase or sale of all or part of QMoney’s business;
• in connection with shipping and related services for purchases made using a Service;
• to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants;
• to banking partners as required by card association rules for inclusion on their list of terminated merchants;
• to credit reporting and collection agencies;
• to companies that we plan to merge with or be acquired by; and
• to support our audit, compliance, and corporate governance functions.

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, QMoney 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.

 

4. How Do We Work with Other Services and Platforms?

A significant benefit of QMoney’s Services is that you can connect your Account with a third-party account or platform. For the purposes of this Privacy Policy, an “account connection” with such a third-party is a connection you authorise or enable between your Account and a non-QMoney account, payment instrument, or platform that you lawfully control or own. When you authorise such a connection, QMoney and the third-party will exchange your Personal Data and other information directly. Examples of account connections include:

• linking your Account to a social media account or social messaging service;
• connecting your Account to a third-party data aggregation or financial services company, if you provide such company with your Account log-in credentials; or
• using your Account to make payments to a merchant or allowing a merchant to charge your Account.

If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases and funds transfers. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Policy.

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 QMoney 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.

5. International Transfers

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 Moldova, we are required to transfer your Personal Data with those parties in order to provide the requested Service to you.

6. How We Use Cookies

Our website uses cookies to distinguish you from other users of our site. This helps us to provide you with a more personalised experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

7. Your Rights and Privacy Choices

You have different choices when it comes to the privacy practices and communications described in this Privacy Policy, many of which may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services.

Choices Relating to the Personal Data We Collect

Personal Data. You may decline to provide Personal Data when it is requested by QMoney, 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 QMoney 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. QMoney will be able to extend the period by a further two months where requests are complex or numerous. If this is the case, QMoney 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?

QMoney will provide a copy of the information free of charge. However, QMoney 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, QMoney 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:

QMoney 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 QMoney 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, QMoney will also inform the individuals about these recipients.

How long does QMoney have to comply with a request for rectification?

QMoney must respond within one month.

This can be extended by two months where the request for rectification is complex.

Where QMoney 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:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
• When the individual withdraws consent.
• When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
• The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).
• The personal data has to be erased in order to comply with a legal obligation.
• The personal data is processed in relation to the offer of information society services to a child.
• There are some specific circumstances where the right to erasure does not apply and QMoney can refuse to deal with a request

QMoney has a legal obligation to obtain data on you meeting with any legal obligations, based on the legal obligations imposed on QMoney, individuals may have no right to erasure, no right to data portability or right to object on the information gathered meeting with QMoney’s legal obligation depending on the service taken.

When can QMoney refuse to comply with a request for erasure?

QMoney 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 QMoney 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, QMoney must also inform the individuals about these recipients.

Your right to restrict processing;

When does the right to restrict processing apply?

QMoney will be required to restrict the processing of personal data in the following circumstances:

• Where an individual contest the accuracy of the personal data, QMoney should restrict the processing until you have verified the accuracy of the personal data.
• Where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and QMoney are considering whether QMoney’s organisation’s legitimate grounds override those of the individual.
• When processing is unlawful, and the individual opposes erasure and requests restriction instead.
• If QMoney no longer need the personal data but the individual requires the data to establish, exercise or defend a legal claim.

QMoney 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 QMoney have disclosed the personal data in question to others, QMoney 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, QMoney must also inform the individuals about these recipients.

QMoney 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.

QMoney will respond without undue delay, and within one month. This can be extended by two months where the request is complex or where QMoney may receive a number of requests. QMoney will inform the individual within one month of the receipt of request and explain why the extension is necessary, if applicable.

Where QMoney are not taking action in response to a request, QMoney 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:

• processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
• direct marketing (including profiling);
• processing for purposes of scientific/historical research and statistics.

QMoney will stop processing the personal data unless:

QMoney 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.

8. How Do We Protect Your Personal Data?

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.

9. Can Children Use Our Services?

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.

10. Changes to this Privacy Policy.

We may revise this Privacy Policy from time to time to reflect changes to our business, the Site or Services, or applicable laws. The revised Privacy Policy will be effective as of the published effective date.

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.

11. Contact Us

You may contact us if you have general questions or concerns about this Privacy Policy and supplemental notices or the way in which we handle your Personal Data.

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 QMoney will be able to extend this period by a further two months, should this be the case QMoney 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 dataprotection@QMoney.com or in writing at QIWI-M LTD, 9, Pan Halippa Street, Chisinau, MD-2009, Moldova.