Privacy Policy 

Last Updated: October 12, 2023

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PURPOSE OF THIS POLICY

This Privacy Policy ("Privacy Policy") explains our approach to any personal or business information that we collect from you or which we have obtained about you from a third party and the purposes for which we process your personal or business information. It also sets out your rights in respect of our processing of your personal or business information.

This Privacy Policy will inform you of the nature of your personal or business information that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services and/or to understand how your personal or business information may be processed by us as a result of providing the Services to you. Please take a moment to read and understand it.

Please also note that this Privacy Policy applies to the use of any personal or business information obtained by us through your use of our Services.

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WHO ARE WE AND WHAT DO WE DO

Moneiva is a technology company that provides services in the supply chain and financial payments.

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HOW TO CONTACT US

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by sending an email to: info@moneiva.com;

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WHAT INFORMATION DO WE COLLECT

We may collect information from you in the course of our business, including through your use of our Site and Services, when you contact or request information from us, when you engage in the services we provide, for personal or business use, or as a result of your relationship with one or more of our staff or clients.

Our primary goal in collecting personal or business information from you is to help us:

• verify your identity
• deliver our Services
• improve, develop and market new Services
• carry out requests made by you on the Site or in relation to our Services
• investigate or settle inquiries or disputes
• comply with any applicable law, court order, other judicial process, or the requirements of a regulator
• enforce our agreements with you
• protect the rights, property or safety of us or third parties, including our other clients and users of the Site or our Services
• with recruitment purposes, and
• use as otherwise required or permitted by law.

To undertake these goals we may process the following information:

• If you are a visitor to the Site:
• Name and job title.
• Contact information including the company you work for, email address and social media account where appropriate.
• Demographic information such as your address, preferences and interests.
• Other information relevant to the provision of Services.
• If you are an individual or business client in receipt of our Services or prospective individual client:
• Name and job title.
• Contact information including the company you work for and email address, where provided, as well as other relevant physical and digital contact information required to provide you the Services.
• Information that you provide to us as part of us providing the Services to you, which depends on the nature of your instructions to Moneiva.
• Relevant information as required by Know Your Client and/or Anti-Money Laundering regulations and as part of our client intake procedures. This may possibly include evidence of source of funds, at the outset of and possibly from time to time throughout our relationship with clients, which we may request and/or obtain from third party sources. The sources for such verification may comprise documentation which we request from you or through the use of online sources or both.
• Information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs.
• Location information required to ensure validity of the information you are submitting to our clients as part of the Services we provide to you and to our client.
• Other information relevant to provision of Services.

Moneiva is primarily engaged by corporate entities and as such those instructors are not data subjects. However, as part of such instructions personal or business information may be provided to us (e.g. personal or business information relating to any of our corporate clients' or prospective clients' officers or personnel, any opponent or vendor or purchaser or personal or business information relating to their legal advisors or personnel, as relevant or similar).

If you are an individual whose personal or business information is processed by us as a result of providing the Services to others (including individual clients and corporate clients) we will process a variety of different personal or business information depending on the Services provided.

We might also need to process personal or business information in relation to other third parties instructed either by our own clients or other persons or companies involved with us providing the Services to our client (for instance other supply chain companies.).

This is a non-exhaustive list that is reflective of the varied nature of the personal or business information processed as part of a technology company providing technology and payment services.

For clients and prospects, we also collect information to enable us to market our products and Services which may be of interest to you. For this purpose, we collect:

• Name and contact details.
• Other business information such as job title and the company you work for.
• Areas or topics that interest you.
• Additional information may be collected such as, but not limited to, events you attend and if you provide it to us, dietary preferences which may indicate data about your health or religious beliefs.
• If you are a potential recruit to join Moneiva:
• Name and job title.
• Contact information including email address.
• Curriculum vitae, including your age and/or gender if you provide it to us, your education, employment history and similar matters and similar information that you may provide to us.
• Other information relevant to potential recruitment to Moneiva.

HOW DO WE USE YOUR PERSONAL OR BUSINESS INFORMATION

We may use your information for the following purposes:

• Fulfillment of Services
  We collect and maintain personal and business information that you voluntarily submit to us during your use of the Site and/or our Services to enable us to perform the Services. Please note also that our Terms of Business apply when we provide the Services.some text
  • What is our legal basis?
    It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you. It is in our legitimate interest or a third party's legitimate interest to use your personal or business information in such a way to ensure that we provide the very best client service we can to you or others.
• Client services
  Our Site uses various user interfaces to allow you to request information about our Services or use our Services including electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal or business information that is relevant to your Service enquiry. This information is used in order to enable us to respond to your requests.some text
  • What is our legal basis?
    It is in our legitimate interest or a third party's legitimate interest to use your personal or business information in such a way to ensure that we provide the very best client service we can to you or others.
• Business administration and legal compliance
  We use your personal and business information for the following business administration and legal compliance purposes:some text
  • to comply with our legal obligations (including any Know Your Client or Anti-Money Laundering or Anti-Bribery, conflicts or similar obligations including, but without limitation, maintaining regulatory insurance);
  • to enforce our legal rights;
  • to protect the rights of third parties; and
  • in connection with a business transaction such as a merger, or a restructuring, or sale.
  • What is our legal basis?
    Where we use your personal or business information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party's legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal or business information to comply with any legal obligations imposed upon us.
• Recruitment
  We use your personal or business information for the following recruitment purposes:some text
  • To assess your suitability for any position for which you may apply at Moneiva including executive positions, associate positions, training contract or summer placements and also any business support or services role whether such application has been received by us online, via email or by hard copy or an in-person application.
  • To review Moneiva's equal opportunity profile in accordance with applicable legislation to ensure that Moneiva does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit.
  • What is our legal basis?
    Where we use your personal or business information in connection with recruitment it will be in connection with us taking steps at your request to enter a contract we may have with you or it is in our legitimate interest to use personal or business information in such a way to ensure that we can make the best recruitment decisions for Moneiva. We will not process any special category data except where we are able to do so under applicable legislation or with your explicit consent.
• Marketing communications
  We carry out the following marketing activities using your personal or business information:some text
  • Postal marketing
  • Email marketing
  • Text marketing
  • Social media marketing
  • We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Client Insight and Analysis section below for more details of the information collected and how it is collected) to send you marketing communications.
  • What is our legal basis?
    It is in our legitimate interest to use your personal or business information for marketing purposes.
    
    We will only send you marketing communications where you have consented to receive such marketing communications, or where we have a lawful right to do so.
• Client insight and analysis
  We analyse your contact details with other personal and business information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services such as the Services you have viewed.
  
  Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal or business information from the computer hardware and software you use to access the Site, or from your mobile. This includes but is not limited to the following:some text
  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site;
  • information regarding your personal or professional interests, demographics, experiences with our products and contact preferences.
  • Our web pages contain "cookies" "web beacons" or "pixel tags" ("Tags"). Tags allow us to track receipt of an email to you, to count users that have visited a web page or opened an email and collect other types of aggregate information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and the relevant Tag.In some of our email messages, we use a "click-through URL" linked to certain website administered by us or on our behalf.
  • By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our registered users like to see.
  • We also use this information for marketing purposes (see the marketing section above for further details).
  • What is our legal basis?
    Where your personal or business information is not in an anonymous form, it is in our legitimate interest to use your personal or business information in such a way to ensure that we provide the very best products and services to you and our other clients.
  • Any other purposes for which we wish to use your personal or business information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details, where available.
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‍WHAT IS OUR LEGAL BASIS TO USE OR PROCESS YOUR PERSONAL AND BUSINESS INFORMATION

It is necessary for us to use your personal and business information;

To perform our obligations in accordance with any contract that we may have with you.

It is in our legitimate interest or a third party's legitimate interest to use personal or business information in such a way to ensure that we provide the Services in the best way that we can.

It is our legal obligation to use your personal or business information to comply with any legal obligations imposed upon us.

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WHO DO WE SHARE YOUR PERSONAL OR BUSINESS INFORMATION WITH

Moneiva is a global technology firm and any information that we collect or that you provide to us may be shared and processed by any Moneiva entity.

We may also share personal or business information with a variety of the following categories of third parties as necessary:

• Our professional advisers such as lawyers and accountants.
• Government or regulatory authorities.
• Professional indemnity or other relevant insurers.
• Regulators/tax authorities/corporate registries.
• Third parties to whom we outsource certain services such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, and document and information storage providers.
• Third parties engaged in the course of the services we provide to clients.
• Third-party service providers to assist us with client insight analytics, such as Google Analytics.
• Third-party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.

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OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

Our Site use certain Tags, log files and other technologies of which you should be aware.

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THIRD-PARTY CONTRACTORS AND OTHER CONTROLLERS

As mentioned above, we may appoint sub-contractor data processors as required to deliver the Services, such as, without limitation, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers, who will process personal or business information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process personal or business information appropriately and according to our legal and regulatory obligations.

Further, we may appoint external data controllers where necessary to deliver the Services (for example, but without limitation, accountants, barristers or other third party experts. When doing so we will comply with our legal and regulatory obligations in relation to the personal or business information, including but without limitation, putting appropriate safeguards in place.

What is our legal basis?
It is necessary for us to perform our obligations in accordance with any contract that we may have with you.

It is in our legitimate interest or a third party's legitimate interest to use personal or business information in such a way to ensure that we provide the Services in the best way that we can.

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WHERE DO WE TRANSFER YOUR DATA TO

In order to provide the Services we may need to transfer your personal or business information to locations outside the jurisdiction in which you provide it.

If you are based within the European Economic Area (EEA), please note that where necessary to deliver the Services we will transfer personal or business information to countries outside the EEA. Our data sharing agreement which is based on the EU standard contractual clauses to ensure we will comply with our legal and regulatory obligations in relation to personal or business information, including having a lawful basis for transferring personal or business information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal or business information.

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HOW LONG DO WE KEEP YOUR PERSONAL OR BUSINESS INFORMATION FOR

For visitors to the Site, we will retain relevant personal and business information for at least three years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation or similar legislation around the world, or for longer if we are required to do so according to our regulatory obligations or professional indemnity obligations.

For Service provision to any client, we will retain relevant personal and business information for at least six years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation or similar legislation around the world, or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.

If personal or business information is only useful for a short period e.g. for specific marketing campaigns, we may delete it sooner than the described above.

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CONFIDENTIALITY AND THE SECURITY OF YOUR PERSONAL OR BUSINESS INFORMATION

We are committed to keeping the personal and business information provided to us secure and we have implemented appropriate information security policies, rules and technical measures to protect the personal and business information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.

All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal or business information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal or business information, are obliged to respect the confidentiality of such personal or business information.

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HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS

You have the following rights in relation to the personal or business information we hold about you:

• Your right of access
  If you ask us, we'll confirm whether we're processing your personal or business information and, if necessary, provide you with a copy of that personal or business information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Your right to rectification
  If the personal or business information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we've shared your personal or business information with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we'll also tell you who we've shared your personal or business information with so that you can contact them directly.
• Your right to erasure
  You can ask us to delete or remove your personal or business information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we've shared your personal or business information with others, we'll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal or business information with so that you can contact them directly.
• Your right to restrict processing
  You can ask us to 'block' or suppress the processing of your personal or business information in certain circumstances, such as where you contest the accuracy of that personal or business information or you object to us. If you are entitled to restriction and if we've shared your personal or business information with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal or business information with so that you can contact them directly. Not that restriction of information processing will likely result in decreased performance of our Services that may require this information to provide the Services.
• Your right to data portability
  You have the right, in certain circumstances, to obtain personal or business information you've provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
• Your right to object
  You can ask us to stop processing your personal or business information, and we will do so, if we are:some text
  • relying on our own or someone else's legitimate interests to process your personal or business information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal or business information for direct marketing purposes.
  • Your right to withdraw consent
    If we rely on your consent (or explicit consent) as our legal basis for processing your personal or business information, you have the right to withdraw that consent at any time.
  • Your right to lodge a complaint with the supervisory authority
    If you have a concern about any aspect of our privacy practices, including the way we've handled your personal or business information, you can report it to the relevant Supervisory Authority.

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

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COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS

The Site contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites' privacy notices as Moneiva has no control over information that is submitted to, or collected by, these third parties.

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CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal or business information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal or business information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal or business information.