Privacy and Cookie Statement
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- Basic Information
- What Personal Data Do We Use?
- What is the Lawfulness and Purpose of the Processing?
- Disclosure of your personal data
- How Long Will We Keep Your Personal Data?
- Users' Rights
- International Data Transfers
- Use of Google Analytics with Anonymisation Function
- Security Measures
- Cookies
- Modifications
1 Basic Information
1.1 About the company
Mi Envío Entidad de Pago, S.L. (hereinafter "Mi Envío") is a Spanish subsidiary of the Transpaygo Group, whose parent company is Transpaygo Limited (hereinafter "Transpaygo").
The financial service is provided by Mi Envío, registered with the Bank of Spain under registration reference number 6926, as a Spanish financial institution authorised to carry out payment services activities as an authorised payment institution under the Payment Services Regulation and to provide services throughout the European Economic Area (hereinafter "EEA").
The technical service is provided by Fonmoney GmbH (hereinafter referred to as "Fonmoney"), which is the Austrian subsidiary of the Transpaygo Group, and provides the Fonmoney domains. The Fonmoney domains are used to provide our Services.
For more information about the Transpaygo Group please see our Terms and Conditions
1.2 About the privacy policy
This Privacy Policy regulates the processing of personal data provided by the User through the Website www.fonmoney.com (hereinafter, the "Website") which is made available to Internet users.
This Policy forms an integral part of the Terms and Conditions and shall be accessible at all times from the Website.
If we change the way we handle your personal data, we will update this policy. We reserve the right to make changes to our practices and to update this policy (or any policy) accordingly at any time, so we encourage you to check back frequently for updates or changes.
1.3 About the controller and the processor of your personal data
The controller of your personal data is Mi Envío Entidad de Pago, S.L., in co-responsibility with Transpaygo Limited, as parent company of the Transpaygo Group, in accordance with the provisions of article 26 et seq. of the European Data Protection Regulation.
Details of data controllers:
- Mi Envío: a Spanish company, with tax identification number B-67412411 and registered office at Avinguda de Francesc Cambó, 17, 1st floor (08003 - Barcelona), duly registered in the Barcelona Mercantile Register in volume 46897, folio 161, page B534639 and 1st entry.
- Transpaygo: a company registered in England and Wales Companies House Reg. No. 8936601 and having its registered office at c/o Keystone Law, 48 Chancery Lane, London WC2A 1JF, United Kingdom.
At the same time, your data will be processed by Fonmoney GmbH, as the owner of the Website, acting as data processor.
If you have any questions or queries about data, or your rights, you can email us at [email protected], and we will ensure that your query reaches the appropriate department.
2 What Personal Data Do We Use?
Personal data, or personal information, means any information about an identified or identifiable individual.
In accordance with current legislation on the protection of personal data, the personal data and information that the user of the Website (hereinafter, the "User") provides when completing any electronic form available on the Website will be included in a database owned by Mi Envío.
In order to make use of our services, it is essential that the User provides a series of personal data. The data that we collect about the User during the registration process - in order to create a User profile on the Website - are:
- Personal data: name and surname, identity card (date of issue, issuing authority, identification number and expiry date), nationality, postal address and country of residence, date of birth, gender and live image or photograph.
- Contact detail: e-mail address, postal address and telephone number.
- Other personal details: occupation, relationship to the beneficiary, etc.
In order to make use of our specific Services, and depending on the service contracted, we will request and process additional personal data (bank details, means of payment used, last digits of your credit card number, financial institution, personal details of the beneficiary of the transaction, bank details of the beneficiary, etc.). Please note that the type of data requested may vary depending on the type of service contracted, the country from which you intend to contract the Service, the country to which you intend to send money, etc.
In all instances, to respect of the principle of data minimisation , only the data strictly required to guarantee adequate provision of the service will be requested.
In accordance with our obligations for the Prevention of Money Laundering, we must advise you that under certain circumstances we may be required to request additional information and documentation from our Users (for example, proof of postal address, proof of origin of funds, bank account statements, etc.). Precisely what is required will depend on the characteristics of the specific transaction.
The data included in each of the forms are voluntary, except for those that are compulsory (indicated as required). Please note that if this mandatory data is not provided, it will not be possible to process the User's request or provide the required service. The User declares under his/her responsibility that the data provided to Mi Envío are true, correct and belong to him/her. Any false or inaccurate statement that may arise as a result of the information and data provided, as well as any damage that such information may cause, shall be the responsibility of the User. Users who provide false information may be excluded from the Website services.
2.1 Information we collect about you:
Server data: To facilitate the service your internet browser transmits various forms of data to us via third-party providers (so-called server log files). These data files that are recorded include:
- Browser add-ons and language
- Date and time of access
- Your Internet Protocol (IP) address
- Details of the transactions you carry out when using our Services, including the geographic location from which the transaction originates.
This data is anonymised and stored separately from the personal data you have provided to us. It is not possible to draw any conclusions about a specific person. The data are analysed for statistical purposes in order to optimise our website and our offers.
3 What is the Lawfulness and Purpose of the Processing?
3.1 Lawfulness of the processing
We will only use your personal data when the law allows us to do so.
The lawfulness on which we base the processing of your personal data is:
- To comply with the contractual obligations arising from the contract entered into with the User.
- When the User has provided his/her express consent, when necessary.
- Where the processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where the processing is necessary to comply with legal and regulatory obligations to which we are subject.
- Where the processing is necessary to protect the vital interests of the User, ourselves or any other natural person.
3.2 Purpose of the processing
The purpose of the processing of such personal data is to create a User profile on the Website owned by the specific customer so that he/she can make use of our Services, and to process the User's request in a timely manner.
The data requested and the specific processing of the same will vary depending on the service requested by the user. Depending on the nature of the service contracted, the purpose of the processing will be to send the requested money, top up a mobile device (TopUp), and in general, to provide the services expressly contracted by the customer through the Website.
In addition, users' personal and contact data is required for customer service purposes, including responding to enquiries or complaints made. This may require the use of certain information relating to the reason for the enquiry (such as the status of a transaction, a technical issue, a product question/complaint, or general questions, etc.). The information provided by the user will be stored for the purpose of processing the request. The data will not be passed on to third parties. Data collected in this way will not be compared with data that may be collected by other components of our website.
Your contact data will also be used to provide you with additional relevant information and content via our newsletter, provided that you have expressly subscribed to it. To receive our newsletter, you need a valid e-mail address. We will check the e-mail address you have entered to ensure that you are indeed the owner of the e-mail address provided or that the owner is authorised to receive the newsletter. When you register to receive our newsletter, we will save your IP address and the date and time of your registration. The data collected in this way is used in our content creation software for the purpose of creating, distributing and analysing the effectiveness of our newsletter. It is not passed on to additional third parties. The data collected in this way is also not compared with data that may be collected by other components of our website. You can unsubscribe from this newsletter at any time. You will find details of this in the confirmation e-mail and in each individual newsletter.
They will also be processed, ultimately, to improve the use of the Website.
Finally, we need to process your personal data, according to our and your legitimate interests, to protect our Customers and the Company of any attempt of fraudulent actions against the platform, Users and/or our Company.
4 Disclosure of your personal data
In addition to Transpaygo Group entities or subsidiaries, we share your personal data with the following types of third-party organisations:
- Service providers. These are external companies that we use to help us run our business (such as KYC providers, payment processing, fraud detection and identity verification, website operations, etc.). Service providers and their selected staff may only access and use your personal data on our behalf for the specific tasks they have been asked to perform, following our instructions. They are obligated to protect your personal data and to only use it for the specific service required. Where permitted by applicable law, you can ask us for a list of the suppliers who process your personal data.
- Supervisory bodies.As an entity regulated by the Bank of Spain, if expressly requested, we may provide your personal data to certain supervisory bodies when required to do so (Bank of Spain, SEPBLAC, FCA, etc.).
As a regulated entity we may also collect personal information in certain situations, such as:
- To comply with legal obligations if regulatory authorities and public bodies request further information about our business, our services or even specific operations.
- In support of anti-fraud, anti-crime or other defensive measures by public authorities, but also by financial institutions, etc.
- In the event of a court order
- In case of total or partial acquisition of the company or its assets.
- In financial risk assessment or commercial risk assessment, data may be transmitted to special providers.
- Debt settlement
5 How Long Will We Keep Your Personal Data?
We will retain your personal data for the period necessary to ensure the proper provision of the contracted service.
Once this period has elapsed, the data will be anonymised, in accordance with the provisions of the data protection regulations and the rest of the applicable regulations, which implies its blocking, being available only at the request of Judges and Courts, the Public Prosecutor's Office or the competent Public Administrations during the period of limitation of the actions that may derive from it in order to be subsequently eliminated.
In general, the personal data provided will be kept for the minimum time necessary to deal with the User's request and to meet the requirements of the relevant regulatory authorities.
6 Users' Rights
The rights of all our Users, their successors, representatives and/or proxies with regard to data protection are those legally provided for and conferred by data protection regulations. Specifically:
- Right of access: you have the right to know what type of data we are processing and the characteristics of the processing that we are carrying out.
- Right of rectification: you may request the modification of your data if they are inaccurate or untrue.
- Right of portability: you can obtain a copy in an interoperable format of the data being processed.
- Right to restrict: You have the right to restrict the processing of your data in the cases provided for by law.
- Right of erasure: you can request the erasure of your data when the processing or retention of it is no longer necessary.
- Right of opposition: you may request the cessation of the sending of commercial communications under the terms indicated above.
- Right to revoke the consent given, provided no requests have been instructed, where requests have been instructed, data will be retained as per stated regulatory requirements.
At any time, Users who have provided personal data to Mi Envío through the Website may exercise their rights regarding the processing of their personal data by sending a written and signed request to the address [email protected] or by post to the address indicated in the heading of this document. The request must indicate the name and surname of the User, address for the purpose of notifications, photocopy of Identity Card or passport and indication of the right being exercised.
Likewise, at any time, the User may object to the use of his or her personal data for commercial purposes by sending an e-mail to [email protected]
Please note that any information you provide to us will only be processed in accordance with, and to the extent permitted by applicable laws.
In addition, please note that, in certain circumstances, we may not be able to delete your personal data without also deleting your User account. We may be required to retain some of your personal data after you have requested deletion in order to comply with our regulatory and legal obligations.
We look forward to dealing with any queries you may have about the way in which we process your personal data. However, if you have a issue to resolve, or are dissatisfied with the solution or response provided by us, you may exercise your right to complain to the competent data protection authorities at www.aepd.es.
7 International Data Transfers
The storage and processing of your personal data as described above may require that they are further transferred/transferred to and/or stored at a destination outside your country of residence, in particular German and France where they are stored.
We will also transfer them to countries outside the European Economic Area ("EEA") (such as to other subsidiaries of the Transpaygo Group, which include countries that have different data protection standards to those applicable in the EEA). We (i) have put in place standard contractual clauses approved by the European Commission to protect your personal data (and you have the right to request a copy of these clauses from Us by contacting Us as set out below) and/or (ii) will rely on your consent where permitted by law.
8 Use of Google Analytics with Anonymisation Function
On our website we use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter "Google". Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site.
The information generated by these cookies, such as the time, place and frequency of your visit to the website, including your IP address, is transmitted to and stored by Google in the USA.
We use Google Analytics on our website with the addition of "gat._anonymizeIp". In this case, your IP address will already be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and thus anonymised.
Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
Google declares that it will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However please note that if you do this you may not be able to use the full functionality of this website.
In addition, Google offers a deactivation add-on for the most common browsers, which gives you more control over the data that Google collects about the websites you visit. The add-on instructs the Google Analytics JavaScript (ga.js) that no information about the website visit should be transmitted to Google Analytics. However, the Google Analytics opt-out browser add-on does not prevent information from being transmitted to us or to other web analytics services that we may use. For more information about the installation of the browser add-on, please click on the following link: https://tools.google.com/dlpage/gaoptout?hl=de
9 Security Measures
Mi Envío has adopted the legally required levels of security for the protection of personal data, installing technical means and measures to prevent the loss, misuse, alteration, unauthorised access and theft of the personal data provided. Despite this, the User must be aware that security measures on the Internet are not impregnable.
Your personal data will be processed by our staff or authorised agents to obtain certain information in accordance with the specific purposes for which it was collected.
We store your personal data in operating environments that use reasonable security measures to prevent unauthorised access. We follow reasonable standards to protect personal data. Unfortunately, the transmission of information via the internet is not completely secure. Although we make every endeavour to protect your personal information, we cannot guarantee the security of data during transmission through our websites/applications.
To assist in maintain data security, there are certain self-protection measures that we expect all our Users to take. It is important that you also do your part to ensure that your personal data is safe and secure. When registering on the Website and creating an account, please ensure that you choose a password that is difficult for others to guess and never give it to anyone else. You are responsible for its confidentiality and for the exclusive use of your account. If you use a public or shared computer, never choose to remember your username/email address or password. Be sure to sign off each time you leave the computer. You should also use the privacy settings or controls we provide on our website.
11 Modifications
It is the obligation of the User accessing the Website to be familiar with Mi Envío's Privacy Policy and to consult it regularly, as it may be subject to change by Mi Envío without prior notice.
The Official Languages of the Company are English and Spanish. Any version of the Privacy Policy in languages other than English or Spanish is offered for the purpose of being more transparent with our Users and with the sole objective of reaching all the markets in which we offer services.
However, in case of discrepancy between the present language and the English and Spanish versions, the provisions contained in the latter shall prevail.