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Privacy policy

This Privacy Policy is an overview of how Global Primex Limited (hereinafter, “We” or “Global Primex” or “Global Primex Limited”) collects, uses, and processes your personal data when you use the website (https://pl.vload.com) (hereinafter, the “Website(s)”), and when purchasing the VLoad e-Voucher solution (hereinafter, the “Services” or “VLoad”)

Please read this Policy carefully, as it becomes legally binding when you use the Services. Global Primex Limited takes privacy and protection of your data very seriously and are committed to handling the personal information with the upmost diligence.

Responsible Authority

The authority responsible for the collection, processing and use of personal data is:

Global Primex Limited

30 St. George’s Street, 3rd Floor, Manor House

Port Louis, Republic of Mauritius

The Website is operated by Global Primex Sp. z o.o., which has been appointed by Global Primex Limited as a commercial agent (hereinafter, the “Distributor” or the “Commercial Agent”). When you enter into the Website (https://pl.vload.com) or you purchase a VLoad e-Voucher, the Distributor will process your data on behalf of Global Primex Limited, which is the ultimate provider of the Services, thus the Distributor shall act as a data processor and Global Primex Limited as a data controller.

If you have any questions about how We protect or use your data, please email us at [email protected]

Data We collect about you

We will collect and process the following data about you:

a) Information you give us:

you may give us information about you when you sign up to use the Service (for example when you provide us with personal details like your name and email address). This also includes information you provide through your continued use of our Services. The information you give us may include, among others: your name, address, email address, phone number, financial information, source of funds, source of wealth, payment details, geographical location, tax identification number and photograph;

b) Information We may collect about you:

We may automatically collect details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;

We may automatically collect technical information, including the IP address used to connect your computer to the internet;

c) Information We receive from other sources:

We may receive information about you from third parties that We are working with closely (for example payment service providers that are collecting the payments you are making for the purchasing of the e-Vouchers, providing us with your basic personal information as well as well as your financial information such as limited information regarding your payment card details);

d) Information from social media networks:

if you log in to our Services using your social media account (for example, Facebook or Google) We will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them. We use such information, together with any other information you directly provide to us when registering or using our Services.

Minor’s data

The Services are directed at adults aged 18 years and over, and not intended for children. We do not knowingly collect data from this age group. Our verification process prevents Global Primex Limited collecting this data. If any data is collected from a child without verification of parental consent, it will be deleted.

How We protect your personal information

We take the safeguarding of your information very seriously, and take a number of steps to ensure it stays secure:

Communication over the Internet between you and Global Primex Limited servers is encrypted;

Our technical security team proactively monitors for abnormal and malicious activity in our servers and services;

We restrict access to your personal information to those employees of Global Primex Limited who have a business reason for knowing such information.

Ways We use your information

We use your information:

to carry out our obligations relating to the contract entered into by the parties for the provision of the Services;

to comply with any applicable legal requirements;

to notify you about changes to our Services;

as part of our efforts to keep our Services safe and secure;

to administer our Services and for internal operations, including data analysis, testing, research and statistical;

to improve our Services and to ensure that they are presented in the most effective manner;

to allow you a refund (or make you a pay-out requested by a merchant) through our Services;

Legal basis for processing

The lawful basis We use for collecting and processing your information are as follows:

Where it is necessary for entering into or performing a contract with you;

Where We have a legitimate interest to do so, provided your rights do not override those interests;

Where you have consented to its uses;

Where required to comply with our legal obligations.

Disclosure of your information

We may share your information with selected third parties including:

affiliates and subsidiaries for the performance and execution of the Services (for example the distributor referred in section 1.2);

payment services providers that are processing your payments and/or are providing payment services needed for the provision of the Services (for example the banks that We are using to receive your payments and to order a credit transfer to your personal bank account);

business partners, suppliers and subcontractors that help us to perform and execute the Services and/or mitigate fraud (for example Refinitiv is the provider of World-Check which is used for AML purposes, or MaxMind which is providing us with a software to collect your IP and prevent that the Services are provided to a person using VPN or any other tool that block and/or disguise the IP);

analytics that assist us in the improvement and optimization of our site;

our group entities or subsidiaries.

We may disclose your personal information to third parties:

such as affiliates, business partners, suppliers and subcontractors for the provision of the Services;

if We are under a duty to disclose or share your personal data in order to comply with any legal obligation;

if We need to enforce the Terms and Conditions or any other applicable agreement;

if We need to protect the rights of Global Primex Limited, including exchanging information with other companies and organizations for the purposes of fraud protection;

to assist us in conducting or co-operating in investigations of fraud or other illegal activity where We believe it is reasonable and appropriate to do so;

to prevent and detect fraud or crime;

in response to a court order, or as otherwise required by law;

If you would like further information, don’t hesitate to write to [email protected]

Sharing and storing your personal data

The Services are provided by Global Primex Limited, an entity duly incorporated in the Republic of Mauritius. When you open a VLoad account or you use the Services, your personal data will be processed by Global Primex Limited. For the avoidance of doubt, by submitting your personal data, you agree to this transfer, storing and processing.

In order to provide our Services to you, We may transfer and store your data at a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your payment order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

It may be necessary for us to transfer your data to the third parties outlined in section 6 that are based outside of the European Economic Area. In these cases, We ensure that both ourselves and our partners take adequate and appropriate technical, physical and organizational security measures to protect your data.

Automated Decision Making

We may use Automated Decision Making (ADM) to help fight financial crime. We may use ADM to verify that your IP location matches with the information regarding your residency that you have provided to us, or to verify that the account holder of your payment method matches with your account details

Cookies

We use cookies for the purposes of ensuring the functionality and security of our Website and our Services. As the processing is necessary for the purposes of legitimate interests, this is, to ensure the functionality and security of the Website and the Services, We are not requiring your consent for this processing.

Data Retention

Given the nature of the Services, We are required to store some of your personal and transactional data beyond the closure of your account with us. We only access your data internally on a need to know basis, and we’ll only access or process it if absolutely necessary. If you want to know more about this, contact us at [email protected]

We will always delete data that is no longer required by a relevant law or jurisdiction in which We operate.

Your rights

You have the right to access information We hold about you, which include, subject to applicable provisions of the data protection legislation, the following:

provide you with a copy of the information that you have provided to us;

provide you with further details on the use We make of your information;

update any inaccurate, incorrect, or out of date personal information We hold;

delete any personal information that is no longer necessary, or no longer subject to a legal obligation to which We are subject to (Global Primex Limited has legal obligations so it may not be possible to delete your data at the time of request. Once the required time has passed then We will be able to comply with your request);

where processing is based on consent, to withdraw your consent so that We stop that particular processing;

adjusting your notification preferences in the settings section of your account;

object to any processing based on ground of the legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime).

If you exercise any of these rights We will check your entitlement and respond in most cases within a month.

If you have any questions in relation to our use of your personal information, contact us at [email protected]

Third-party links

Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.

Changes to our privacy policy

We may revise this Privacy Policy at any time without notice provided that is needed to keep up with changing legislation. Likewise, We may revise this privacy Policy at any time without notice for the purposes of keeping up with best practices and changes in how We process personal information, provided that is for your interest or when the applicable legislation entitles us to do so. We will post the revised version on this website and when possible, We will notify you via email or via push-up notification when you will access your account. In all other cases, We will revise this Privacy Policy as per the legal requirements of the applicable legislation.