Privacy Policy
September 2024
This website (“Website”) is operated by GlobePay Limited (“GlobePay”, ”we” or “us”) and we are committed to protecting and respecting your privacy.
This policy (together with our Terms of Service and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of data protection legislation, the data controller is GlobePay Limited, registered address: 23 Franklin Building, 10 Westferry Road, London, England, E14 8LS.
Personal information is information that can be used to uniquely identify a single person. We also collect non-personal information, or may anonymise personal information in order to make it non-personal. Non-personal information is information that will not allow a specific individual to be identified. We may collect, store, use, transfer and disclose non-personal information for any purpose; for example, the use of aggregated transactional information for commercial purposes.
We will collect and process the following data about you:
• Information you give us. This is information about you that you give us by filling in forms on our website globepay.co (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service(s), search for a product, and when you report a problem with our site. The information you give us may include your name, date of birth, address, e-mail address, phone number, financial and bank account information, personal description, and photograph. If you give us information on behalf of someone else, you confirm that you have given them the information set out in this notice and that they have given permission for us to use their information as set out in this notice.
• Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
i. technical information, including the Internet protocol (IP) address;
ii. information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
iii.your location.
• Information we receive from other sources. We may receive information about you from a source other than you and the information is protected under this privacy policy. We will provide an easy way to access the privacy information. Under certain circumstances, we will not disclose privacy information, including:
i. You already has the information
ii. providing the information to you would be impossible
iii. providing the information to you would involve disproportionate effort
iv. providing the information to you would render impossible or seriously impair the achievement of the objectives of the processing;
v. we are required by law to obtain or disclose the personal data; or
vi. we are subject to an obligation of professional secrecy regulated by law that covers the personal data.
What processing grounds do we rely on?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the agreement, we are about to enter into or have entered into with you (for example, to provide you with any products and/or services which you have requested);
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (for example, undertaking analysis and research for the purposes of improving our website user experience); and
• Where we need to comply with a legal or regulatory obligation (for example, equal opportunities monitoring).
Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
We use information held about you in the following ways:
Information you give to us. We will use this information:
• to carry out our obligations arising from any agreements entered into between you and us and to provide you with the information, products, and services that you request from us;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
You agree that we have the right to share your personal information with selected third parties including:
• business partners, suppliers, and sub-contractors for the performance of any agreement we enter into with them or you;
• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
• analytics and search engine providers that assist us in the improvement and optimisation of our site;
• credit reference agencies for the purpose of assessing your credit score;
• compliance vendors for the purpose of identifying and verifying your information where this is a condition of us entering into an agreement with you.
We will disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If GlobePay or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of GlobePay Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and risk reduction.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Where we have given you (or where you have chosen) a password or access code which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and you authorise us to act upon instructions and information from any person that enters your user id or password.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our site 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 or liability for these policies. Please check these policies before you submit any personal data to these websites.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
• Strictly necessary These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance They allow us to recognise and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. This is statistical information and does not identify any individual.
• Functionality These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that third parties (including, for example, providers of external services like web traffic analysis services, or social media websites) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
If you wish, you can set your browser to notify you before you receive a cookie so you have the chance to accept it and you can also set your browser to refuse to receive or send all cookies. The website www.allaboutcookies.org (run by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users. Please be aware that if you do not accept cookies our website may not function correctly.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including (1) comply with law; (2) provide the GlobePay services, and; (3) pursue our legitimate interests, including detecting and preventing fraud and financial crimes, enforcing and defending our legal rights, complying with valid legal process requests from courts or competent authorities, improving the quality of our services, and promoting our products and services as appropriate and as permitted by applicable law and agreements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
GlobePay will generally keep Personal Data we obtain for a period of five or more years from the end of the business relationship with you, or the date of the last transaction, whichever is later. We may also hold your personal information for longer where it is necessary to do so for the management of any active or potential legal proceedings, to resolve or defend claims, and for the purpose of making any necessary remediation payments.
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@globepay.co.
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©2018 GlobePay Limited is authorised and regulated by the UK Financial Conduct Authority(FCA), with the Firm Reference Number (FRN) 930172.
