Last updated: 23/05/2018
What makes SafiMoney the best way to manage all your financial needs worldwide are trust and security.
In this policy, we explain how SafiMoney collects, manages, uses and protects your data.
1. What is SafiMoney?
SafiMoney is an online financial ecosystem offering services to but not limited to wallet, international money transfer, online payment, bonus program in an easier, faster and cheaper way.
The term « Service » refers to not limited to wallet, international money transfer, online payment, bonus program enabled from our website or mobile app.
In the language of data protection regulation, Clean Group is the « data controller » of your personal data and you, our customer, are the « data subject ». This means that Clean Group determines the purposes and means of processing your personal data, while respecting rights concerning your privacy.
2. What data do we collect?
We collect various types of data about our customers or their respective companies. Some of it may be considered personal data, which means data that make you identifiable as an individual or a company.
We are bound by the legal requirement to collect, verify and record certain data about you or your company (s) or the recipients of your transactions. All types of data we gather may be used to prevent or detect crime.
Data we may collect, and use are as follow:
- Basic personal data, such as (but not limited to):
- Date of birth
- Phone number
- E-mail address
In addition to the above data, we collect for company or business registration following information:
- Company name
- Number of employees
- Trade license
These data are necessary to provide the Service to you. We will request this data when you sign up before the Service is provided.
- Data for ‘Know Your Customer’ (KYC) regulations, such as (but not limited to):
- Proof of your identity, like a passport, driving licence, national ID card (both sides) or residence permit
- Proof of your address, like a utility bill or bank statement
- Additional details on the source of funds being sent, like a payslip, credit card statement, tax rebate receipt or bank loan agreement
This data will sometimes be needed to conduct Know Your Customer (KYC), Customer Due Diligence (CDD) and security checks, as required by local and international regulations. This helps us keep your money safe, and we will only request these details when necessary.
- Data about your recipient, such as (but not limited to):
- Date of birth
- Phone number
- Proof of their identity, such as a passport, driving licence, national ID card (both sides) or residence permit
- Data from other third-party sources, such as (but not limited to):
- Facebook, Twitter or Google profile images and names
- Banks and payment service providers used to top up your wallet or transfer money to us
- Advertising networks
- Search engines providers (such as Google)
- Credit reference agencies
Clean Group collects this data only when you provide the relevant permission to social media sites.
- Technical data, such as (but not limited to):
- Page views
- App downloads
- Operating system
- Browser type
This data is used to help us to understand how you use our Service, so that we can improve it.
3. Why do we collect your data?
We collect your data to personalise and improve our Service for you. The specific purposes for which we collect your data include:
- Transactional purposes
We need to collect data in order to process your transactions. Without data such as you and your beneficiaries bank account details or full name and address, we would be unable to transfer money for you.
- Regulatory purposes
As regulated financial institutions, both Clean Group and our partners are required to conduct Know Your Customer (KYC) and Customer Due Diligence (CDD) checks to comply with our legal and regulatory requirements. These include our requirements under Anti Money Laundering (AML) and Counter Terrorist Financing (CTF) legislation. All of this helps us keep our Service safe and secure.
- Marketing purposes
We may process your personal data to provide you with certain types of marketing communication with a more personalised Service that we believe will be relevant and of interest. This kind of activity is permitted by our ‘legitimate interest’ which is described in a later chapter in this policy. We will always endeavour to make these communications relevant and unintrusive, and you are able to object to marketing communication from us at any time.
- Analytical purposes
We may collect and analyse data such as website or app visit logs in order to improve the quality of our Service.
You do not have to disclose any of the above data to us. However, if you choose to withhold certain data, we may not be able to provide you with our full Service.
4. How do we keep your data safe and secure?
All the data that you provide to us is encrypted on our secure servers. We restrict access to your data to specific employees of SafiMoney who have an important business-related reason for handling it. Our communications are encrypted using the latest TLS (Transport Layer Security) technology protocol. We also use the mechanism of the proven blockchain technology to make our system more robust.
5. How long do we keep your data?
Depending on what purpose your data is used for, the length of time we keep it may vary. Either way, we will only hold your data as long as necessary to serve the purpose it is used for.
We are legally required to keep the data obtained for Know Your Customer (KYC), Customer Due Diligence (CDD) and security purposes (including transaction records and our communications with you) for at least five years after the most recent transaction.
- Legitimate Interest
When the five years’ retention period and/or legitimate interest no longer apply, we will remove your data from our system. For more information on legitimate interest, please see Section 8 of this Policy.
In situations where you give us specific consent to process certain kinds of data, you are able to withdraw that consent at any time. We will then stop processing your data and, if the five years’ retention period and/or legitimate interest retention period does not apply, we will also erase your data from our system.
We may retain any data mentioned above for a longer period, if required to protect the rights, property or safety of SafiMoney or of the Service provided by us or our partners.
6. Who do we share your data with?
We share your personal data with third parties only when it is necessary for the fulfilment of the Service or to comply with applicable laws.
We will never sell your personal data to other organisations.
As part of our bonus program, only your first name will be considered and added to the tree of the one who recommended you. This limits and prevents a direct identification on your identity.
We work with partners who help us to complete your transactions. If they are based outside the EEA, we will share your personal data with them only when they apply essential safeguards, or if it has been established by EU institutions that the relevant country has an appropriate data protection regime in place, or when we otherwise ensure that the appropriate level of protection is applied for data processing.
The following are some purposes for which we may share your data with third parties:
- To fulfil the contract between you and us
We may share your data with third parties, such as our partners and intermediaries, when they are necessary for the fulfilment of the Service.
- When required by law
We may share your data, for example for the purposes of security, taxation and criminal investigations.
- For marketing and analytical purposes
We may share your data with third parties such as providers of customer service tools, marketing campaign tools, email communication tools, analytics software and data visualisation tools.
If we sell or buy any business or assets, we may be obliged to share your personal data with the prospective seller or buyer.
7. What are your rights?
There are certain exceptions where your rights may be superseded by laws and other requirements applicable to regulated financial institutions like us. An example of this would be the obligatory retention period (seen Section 5), which supersedes the right to data erasure. Nevertheless, the law gives you a number of important rights in relation to your personal data, which are listed below.
You have the right:
- to be informed: the right to be informed about how we use your personal data
- of access and data portability: the right to request access to the data that we have about you, to obtain the data within a month of asking for it, and to use it for your own purposes
- to rectification: the right to correct, amend or update your personal data if it is wrong or has changed (this can usually be done using the settings provided on your account)
- to erasure: the right to ask us to remove the data we hold about you from our records
- to be forgotten: the right to request erasure of any links to your personal data, or of any copy or replication of any public personal data
- to restrict processing: the right to ask us to stop processing your personal data
- to object: the right to object to data processing, if you believe that our legitimate interest might infringe upon your rights
- related to automated decision-making and profiling: the right not be subject to individual decisions made solely by automated means.
- to notification in the event of breach: the right to be immediately informed if we identify a data breach
- to raise a complaint: the right to contact our Data Protection Officer if you are not happy with how we have handled your personal data
- to lodge a complaint with a supervisory authority: the right to submit a complaint to the Information Commissioner’s Office (ICO) if you are not satisfied with our Data Protection Officer’s response, or if you believe that we are not processing your personal data in a lawful way
If you would like to read more about your rights in relation to your personal data, please send an e-mail to [email protected]
8. Legitimate interest
Legitimate interest is a specific legal justification for the collection and processing of your personal data. It applies when we have reasonable grounds to collect and/or process your personal data to improve our Service, as long as this does not infringe on your rights.
Our legitimate interest may justify some examples of automated decision-making. One of those is our estimated transaction timing, which we use to determine the time in which the transfer will reach your beneficiary.
We believe that if you are an active customer of SafiMoney, it is in your interest to receive occasional information about our Service. We may therefore send you communications about offers or promotions that we believe are relevant for you based on your previous use of the Service. If we notice that you are having problems using our Service, we may on our own initiative decide to contact you, in some cases by phone, to offer help.
We may also process your data to help develop new product features that we believe will improve the Service. We may contact you occasionally to assess your satisfaction with the Service. We may also use your data to determine the effectiveness of marketing or promotional campaigns. We may also contact you with information about any changes in the Service, and/ or other important updates.
We will only share anonymised or encrypted data with the third parties. We may also provide our partners with anonymous aggregated data about our customers for marketing and analytical purposes, to help optimise our marketing communications.
You can object to data processing based on our legitimate interest at any time by contacting us at [email protected] or by changing the settings on your SafiMoney account.
9. Cookies Policy
11. Contact details
You can contact SafiMoney:
SafiMoney has a Data Protection Officer who is responsible for matters related to privacy, data protection and data security. Our Data Protection Officer can be contacted at [email protected].