Last Update – 23.11.2020
Albercom Ltd, a company registered under the number 512329186, operating the Services of moneysend (via the website moneysend.co.il, the “Website“) is currently regulated as a monetary service provider and pending the approval as a financial asset service provider under the Israeli Law (hereinafter the “Company” or “We“), respects the privacy of its users (hereinafter the “User” or “You“). Protecting your personal information is fundamental to us.
1. Scope and Consent
All terms in capital letters that are not defined in this Policy shall have the meaning assigned to them in the Terms and Conditions by which You are also bound.
By accepting this Policy, You hereby authorize us to collect, record, and use information in accordance with this Policy, whether by Us or any company included in our group of companies, as the case may be.
We remind You that a User must be over the age of 18 in order to process Transactions and to consent to the processing of Personal Information as defined below. Should You break this mandatory requirement, the Company rejects any claim of liability as it never knowingly intended or attempted to solicit or receive information from children.
Any Personal Information provided by You constitute a declaration on your side of its accuracy and truthfulness and we are entitled to rely on it.
“Personal Information” is defined as the information procured by the User in respect of himself and/or of the Recipient and comprises identification data which may include the first names and last names, country and city of residence, birthdate, ID number, phone number, as well as other information depending on the local legislation of the place of the Recipient, and potentially the payment related data to the use of the Services such as the credit or debit card number. Depending on the local legislation of the Recipient, we may also be required to ask You the purpose of the transfer and the frequency of Transactions. We will also record the date and time, amount and currency of the Transaction, as well as technical data such as IP address of the device information, browser type, operating system or and GPS location from the used device, and derived data that would enable the profiling of the User or of the Recipient.
We may also record our communications, whether by emails or phone, as part of such Personal Information.
Note that we may also receive certain technical traffic data on our server logs.
You shall read fully and carefully this Policy and approve it before the completion of each Transaction or the use of our Services. This Policy shall govern our relationship in respect of your Personal Information and applies to any User that has filled in information even without fully completing the transaction process, whether the User has done it from a computer or a mobile device. The Policy also governs any email, electronic messages including SMS, telephone conversation or any other communication between You and Us in relation to your Personal Information.
Please note that you are not obliged by law to provide us with any Personal Information however We cannot provide You our Services without processing, recording and using such Personal Information.
You will be notified upon any material change of this Policy and will be required to approve it again.
2. How We collect Your Personal Information
2.1. We may collect, receive and process any Personal Information You provide us during your performance of a Transaction, or also when You communicate with us.
2.2. We may also collect Personal Information through automatic means, for instance by using cookies, and regarding your use of our Website. That may include your IP address, your browser ID, your location data. We may use third party service providers in order to process such data, notably to assess the existing traffic on our website.
2.3. In order to fulfill our legal obligation to prevent fraud and money laundering, We may also obtain information, including Personal Information about You from third parties and our trusted service providers.
2.4. We may also indirectly collect information on You from other sources such as partners or financial institutions which are related to your funds or to the Recipient’s funds.
2.5. Our right to collect your Personal Information is based on: Your express consent to such collection; our compliance with any legal or regulatory requirement to which we may be subject, such as the applicable regulations against money laundering and financing of terror; our legitimate interest to process data, however not overriding your own rights and freedoms; and the necessity and appropriateness to perform our obligations towards You.
2.6. The collection of your Personal Information also enables us to perform our Services and improve our customer services.
3. How We use your Personal Information
We may use the information collected, including your Personal Information, for several purposes and in any of the following ways:
- To provide You with our Services, including the fulfillment of our obligations towards You and the sharing with our partners and any third parties necessary for the performance of our Services;
- To perform any necessary financial and identity checks, fraud prevention checks, anti-money laundering and credit checks, including examination of your request for Services according to legal regulatory requirements, whether in Israel or in the local jurisdiction of the Recipient, but also risk management examination and fraud detection, whether by us or through our trusted third parties, and You give your irrevocable consent to it, including in respect of the Recipient;
- To provide reports that include your Personal Information to anti money laundering authorities, and to any other competent authority of any relevant jurisdiction, in accordance with legal requirements, without any possible claim from You against the Company in this respect;
- To enforce the rights and obligations under our Terms and Conditions, whether it be ours, yours, or any other third party’s rights.
- To keep the records of your Transactions, with the relevant details, including the recipients and you consent to such records on your behalf and on behalf of the recipient, and waive any claim in this respect.
- For our purposes based on the use of aggregated transactional information and anonymised information for commercial purposes, services and surveys, statistical data research and analysis, and using external companies which gather and analyse statistical information; this use of aggregated and anonymised information would not allow a user identification by third parties;
- To draw patterns of use of the Website and to use such data in order to improve our Services, their operation and contents,
- To deliver marketing and/or other notices and updates and to improve the customisation of the Website;
- To improve the quality of the Services, and of our customer service, including answering questions and responding to feedback;
- To send communications, administrative or promotional e-mails or SMS and/or reaching You via social media platforms, with respect to Services that may be of your interest based on information in our possession. Should You not wish to receive marketing messages from us, you can inform us at any time by contacting us at [ ] or by choosing to opt out of receiving additional promotional e-mails from us by clicking on the ‘unsubscribe’ link in any such e-mail, or by following any instructions Company may include in the message sent to You (the “Opt-out Request”). Please note that, once We receive such Opt-out Request, it may take an additional period of time for it to become effective. Note that, if You opt-out of our promotional communications, the Company may still communicate with You from time-to-time, if the Company needs to provide You with information or for other non-marketing reasons related to the Services.
Please be informed that no automated decisions or profiling are made in the course of the processing of your Personal Information.
4. How do We disclose information to third parties
4.1. Unless otherwise provided in this Policy, We will not disclose your Personal Information to third parties.
4.2. We may share your Personal Information or any other non-personal information with third parties in order to provide You with access to our Services, with suppliers working on our behalf, based on your consent or on a legal requirement or authorization.
4.3. We may also share your Personal Information or other non-personal information with third parties to comply with our legal obligations, to prevent any fraudulent or illegal activities related to our Services, to respond to legal process or to protect the rights or property of the Company, of our customers or of others. We attempt to minimize the amount of personal information We disclose to what is directly relevant and necessary to accomplish the specified purposes.
4.4. We may disclose to third parties the Personal Information gathered about You via the Website and the Services, where this data identifies You personally, notably in the following cases:
- To collect, hold and manage your Personal Information through Company’s trusted service providers (and their subcontractors) operating under suitable safeguards to protect the privacy and security of your Personal Information, for example, cloud computing platform and hosting services provider, as reasonable for business purposes, including when located in a country that does not have the same data protection laws as in your jurisdiction;
- To partners and financial institutions that take part in the processing of the Services, including Credit Card service providers, credit institutions, any other financial institution where You or the Recipient have an account in order to process the Transactions;
- Risk management, by using trusted third parties in order to secure the Transactions, to perform identity checks, to perform any fraud check or money laundering detection or any other potential illegal activity – for instance any listing checks service providers such as World Check by Thomson Reuters;
- To communicate with You and provide You our customer support;
- To provide information to our authorised representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, security and other requirements;
- To improve our Services, notably by using aggregated information of your use of the Website and sharing this information with third parties to improve and support our Services and to make certain features of the Services available to You;
- To promote the use of our Services. Sharing your contact information with our trusted service providers that assist us in sending notifications, marketing, advertisements and customer service, including via social media platforms. You can stop receiving our promotional messages by choosing the Opt-out Request and unsubscribe or by contacting us at [email protected].
- To satisfy applicable laws and regulations, if and as applicable, including reports to Anti Money Laundering Authorities and to any other competent authority, including especially in the jurisdiction of the Recipient, in accordance with legal requirements, reports to financial institutions that take part in the Services for compliance purposes, and to comply with a judicial proceeding, court order, or legal process;
- To enforce the Terms and Conditions, including investigation of potential violations thereof, and to protect against harm to the rights, property or safety of the Company, its Users or the public as required or permitted by law;
- Should the Company go through a business transition such as a merger, acquisition of all or a portion of the Company’s assets, your Personal Information may be among the assets transferred and it will be transferred only subject to restrictions similar to those contained herein or as otherwise required by applicable laws and regulations.
Please note that these third parties may be located in other countries where the laws on processing Personal Information may be less stringent than in your country.
Unless it is permitted as stated, the Company does not sell, rent, share or otherwise disclose Personal Information to third parties. Nevertheless, the Company may disclose or otherwise use information that qualifies as non-personal information at its own discretion.
5. How We store your Personal Information
5.1. Your Personal Information may be transferred to, stored at and processed in a destination outside our jurisdiction (Israel) and/or outside the European Economic Area (“EEA”), where your Personal Information may not be protected by the same legal standards. We endeavor to take all steps reasonably necessary to ensure nevertheless that your Personal Information is treated securely and in accordance with this Policy, including the use of any adequacy mechanisms required by law to ensure that the transfer is lawful.
By using our Services and accepting this Policy, You hereby agree to this transfer, storing or processing and waive any claim in this respect.
5.2. The reasons for such transfer, processing and storage outside our jurisdiction and the EEA are as follows:
- Our hosting service provider or cloud computing platform may be located outside our jurisdiction or outside the EEA.
- We may use partners outside our jurisdiction or the EEA for the performance of the Services;
- Anti-fraud agencies, credit reference agencies and other service provider that are based outside our jurisdiction or outside the EEA, require access to your information, including Personal Information, to perform their obligations;
- Staff performing the processing may be operating from outside our jurisdiction or outside the EEA, and they may participate either in the Transaction processing, in support services or else. We nevertheless take the steps to ensure that our staff respects and treats your Personal Information in accordance with applicable law and with this Policy.
5.3. Notwithstanding the above, You acknowledge that the request to perform a Transaction to a Recipient located outside our jurisdiction and outside the EEA constitutes per se a conclusive evidence of your consent to transfer Personal Information, whether it be yours or the Personal Information of the Recipient to the country where the Recipient is located. You further declare that you have obtained the necessary consent of the Recipient to have his Personal Information transferred by You.
6. Data Retention
We may retain your Personal Information in conformity with applicable laws in order to comply with our legal requirements and/or to protect Company’s legal interests, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce the Terms and Conditions and take other actions otherwise permitted by law.
When such retention period has elapsed, your Personal Information will be deleted in accordance with our procedures.
In addition, we will retain your Personal Information even if a Transaction request is cancelled, or if your Transactional process is declined or abandoned, for as long as not prohibited under any applicable law, for legal, regulatory, fraud and other financial crime prevention.
7.1. Cookies are alphanumeric identifiers that are transferred to and stored in your electronic device through your web browser for record-keeping purposes. Some cookies allow making it easier for you to navigate, while others are used to enable a faster log-in process or to allow to track your activities.
7.3. When you access the Website, you will be presented with a message bar requesting your consent to set those cookies, or to define the parameters for the cookies. You are responsible for your decision in respect of allowing and/or configuring the cookies. By continuing to browse the Website You are enabling us place cookies on your device and/or our partners to provide a better experience and service to You.
7.4. Our website may place the following type of Cookies:
- Essential cookies: These cookies are necessary to allow you access and move around our Website and use all its features. Without these cookies, you would not be able to access our Website and/or to use certain important features.
- Visitor Cookie: These cookies are part of our security mechanism and are used to identify visitors (visitor representing a specific computer/phone device) of the Website,
- Analytics cookies: The Website also uses analytics cookies placed by Google Analytics (including Google Tag Manager) to measure the number of visits and the parts that are the most popular among our Website visitors as well as for benchmarking purposes. This information is used to provide aggregated and statistical information on the use of the Website and is used to improve the contents of the Website to enhance your user experience. To opt-out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout/ (or to other Google link as may be updated from time to time)
- Advertising cookies: These third-party cookies, such as Google Adwords, help ensure that our advertisements are as relevant to you as possible. These cookies track and record information (including by Google) regarding your browsing habits and activity, and use this information to enable us to show you relevant/personalized marketing content across the Internet. Using these cookies, our third-party service providers may collect personally identifiable information (for instance when information collected by such cookies is associated with your Google Account) and use this to display our targeted advertising to You. For example, some advertising cookies help select advertisements that are based on your interests. You can opt out of Google’s use of the abovementioned cookies by visiting Google’s Ads Settings: https://adssettings.google.com/authenticated (or other Google link as may be updated from time to time).
You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed.
8. Third Party Services
8.1. The Company is entitled to be assisted by third parties, including advertising companies, in order to display advertisements on the Website and those third parties may use information about your online activity (which does not include identifying Personal information), notably to provide You with advertisements for products and services which may interest You.
8.2. Notwithstanding the above, You hereby acknowledge that you are aware that your activity on the Website may enable third parties, such as online search engine, to rely on, and use, the nature of your activity as stated, in order to present You advertisements in the framework of online activity, even outside of the Website, as an inseparable part of their ongoing activity and without any relation with the Company’s activity.
8.4. The Services may also contain links to third party websites and services, which are outside the Company’s control and are not covered by this Policy. The Company does not assume responsibility for the privacy practices of such other applications or websites to which it may link, and encourages you to review those privacy policies yourself.
9. Security Precautions to protect your information
9.1. Our utmost care lies with the implementation and maintenance of reasonable security procedures consistent with prevailing industry standards to protect the security of the Website, the Services, and our Users’ Personal Information or other information from accidental loss and from unauthorised access, use, alteration and disclosure.
9.2. We have set up procedural safeguards designed to try to prevent potential unauthorised access and misuse of the information that We process and store. We further limit the access to your Personal Information to Our employees that are trained about the importance of confidentiality and privacy of customer information and only that are in need to have access to your Personal Information.
9.3. While We take reasonable precautions against possible security breaches of the Services, no website or internet transmission is completely secure, and We cannot guarantee (i) that unauthorised access, hacking, data loss, or other breaches shall never occur; and (ii) the security of your data, including Personal Information, while it is being transmitted to and from the Services. Any transmission is at your own risk. The Company urges You to take steps to keep your Personal Information safe while logging on our Website and using our Services.
9.4.You are responsible for keeping the confidentiality of any code received by SMS during the Transaction process from our Services or from credit card companies, partnering with us (Isracard, C.A.L, Max, etc.) and complying with our instructions or those credit card companies’ instructions. You must not share any codes and/or credentials with anyone else, and You authorize the Company to act upon instructions and information from any person that enters Your Israeli ID number and/or any person having completed the Transaction using your credit card credentials according to the rules of 3D Secure payments. You further acknowledge that the Company is entitled to act in reliance that you are the author of the said instructions when Your Israeli ID number is recorded.
9.5. You also agree to promptly notify us of any reason to suspect that your Personal Information has been compromised.
10. Terms and Conditions
Please also review and accept the Terms and Conditions section establishing the use, process, as well as disclaimers governing the Services, available on our Website.
11. Your Privacy Rights
You may have certain rights under data protection legislation including the right to see the Personal Information held about You and You may ask us to make necessary changes to ensure that it is accurate and up to date. Where applicable, data protection legislation may also provide the following rights in relation to Personal Information:
- request us to give you access to it;
- request us to rectify inaccurate or incomplete information, or erase it, where applicable;
- request us to restrict or to stop our using it, in certain circumstances;
- withdraw your consent to our using it;
- data portability, in certain circumstances;
- opt out from our direct marketing, if applicable; and
- lodge a complaint with the relevant Data Protection Authority.
Dealing with the requests You may have in respect of your rights shall be in principle free of charge, however We reserve the right to charge a reasonable fee notably where the request appears to be manifestly unfounded or excessive, or burdensome, in particular because of its repetitive character, in which cases We may also choose to refuse to act.
The Company is entitled to verify, according to its procedures, the identity of each person sending a request before answering to it.
To proceed with a request, You may contact us as indicated in our Website.
12. Changes to our Policy
13. Contact us
If you have any additional questions or concerns about this Policy, please feel free to contact us any time through the Services as indicated in the Website.