Privacy Notice

Description

This Privacy Notice explains what information we collect about you, how we will use that information, who we will share it with and under what circumstances we will share it. It will also explain what we do to keep your information safe. It should be read alongside the terms and conditions you have for the product or service we are supplying to you.

1. INTRODUCTION & OVERVIEW 

1.1. This Privacy Information Notice explains what information we collect about you, how we will use that information, who we will share it with and under what circumstances we will share it. By accessing this website (our site) you are accepting and consenting to the practices described in this policy. 

1.2. Our website 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 security measures and that we do not accept any responsibility or liability for these policies. 

2. WHO IS PROCESSING YOUR PERSONAL DATA

MSL EDGE EUROPE LTD (hereafter “MSL”) is a global platform supporting multi products and services and will be acting as the processor of the data in relation to the processing activities. 

2.2. MSL collaborates with Payment Service Providers (PSP) and E-Money Institutions (EMI), which are the issuers of your Card, acting as Data Controller in relation to the processing activities described on their Data Privacy Policy. 

3. PERSONAL DATA INFORMATION

3.1. Personal data is any information that relates to you, and it can be either provided by you or collected by us, where if we do not collect this personal data, we will not be able to provide you with our products and services. 

3.2. The information you will provide us, is all that information about you that you will give us by completing all the forms, by email, or by phone. This information includes: 

3.2.1. Name and surname, address, date of birth, and any other personal information such as contact data (telephone numbers). 

3.2.2. Information related to your ID Documentation such as the Nationality, Country of Issuance, Document Number, Date of Issuance and/or Expiry Date, including a photograph. 

3.2.3. Platform Access Data including your Username and Password, or biometric details used for accessing the platform or confirming transactions. 

3.3. The information we collect from you, with regards to the access to the platform or to the visits to our sites such as: 

3.3.1. Technical Data which includes your log in data, browser type and version, 3 PRIVACY POLICY MSL EDGE EUROPE LTD time zone setting, location, Internet Protocol (IP) address, operating systems and platform. 

3.3.2. Data Information about the usage of the platforms or website visits, including the URL, browser of our websites, page responses times, errors occurred, page interaction information (such as scrollings, clicks, etc..) and any contact details left in the website. 

3.3.3. Financial and Transactional Data including Bank Account Details, Payment Card information, and all the details of the payments and transactions conducted using our platform. 

3.4. We collect and receive from other sources different types of personal data about you, but we will only collect the information that we need to enable us to deliver the product or service we are providing you with. The information we receive from third parties are necessary to conduct our business and we will inform you previously to obtain this data. 

3.5. Personal information may be gathered in order to conduct customer due diligence checks in line with the risk financial crime, screen new business applications, existing customers and incoming/outgoing payments to comply with the international laws on sanctions, combatting terrorism and other financial crime. 

3.6. Please note we may process your personal information and data without your knowledge and consent when this is required and/or permitted by the current law but this usage won’t be related to marketing communications where we will always seek your consent before conducting any commercial communications. 

3.7. In compliance with art. 25.1 of Law 10/2010, MSL shall keep for a period of 10 years from the execution of the transaction or the termination of the business relationship the documentation formalizing compliance with the obligations in terms of prevention. Five years after the termination of the business relationship or the execution of the occasional transaction, the retained documentation shall only be accessible by MSL’s internal control body, relevant regulated services providers and, where appropriate, those responsible for its legal defense. 

4. HOW ARE WE USING YOUR DATA AND INFORMATION 

4.1. MSL will have access and usage of your data in order to perform the contract we have entered, or we are about to enter with you to provide you services in regards our processing platform and programme management services. 

4.2. MSL will process and usage your personal data where it is in the legitimate interest 4 PRIVACY POLICY MSL EDGE EUROPE LTD to do so. At this stage, MSL will make sure that your rights and freedoms are not override. 

4.3. MSL will have access and usage of your data where it is necessary to accomplish with any legal or regulatory obligations, including those where MSL is required to disclose information by, or to, a court or regulatory authority, or law enforcement agencies. 

4.4. To fulfil our tax and regulatory reporting obligations. 

4.5. If further information on this topic is required by you please contact us into dpo@themsl.com. 

5. CONSENT 

5.1. MSL may, at times, request your consent to process your personal data for specific reasons, such as: 

5.1.1. Where we wish to provide you with marketing information in relation to our products and services, or partner company products or services, which we believe may be of interest to you. We will only contact you for direct marketing purposes where you have specifically consented, and you may opt out of direct marketing at any time (see the section called Your rights in relation to your personal information below). 

5.1.2. Where you have appointed a third party to represent you and deal with us on your behalf and we need to share your personal data with them. 

5.1.3. Where we need to process your biometric data to verify your identity when you open or operate an account. In such cases we will ask for your explicit consent. 

6. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA INFORMATION 

6.1. You have significant rights in respect of the way we process your personal data and we have significant obligations with regards to your rights. 

6.2. You have the rights to find out what personal information we hold about you, and you can request that we correct and or update any inaccurate and incomplete information about you. 

6.3. You have the rights to: 

6.3.1. To access to your personal information. 

6.3.2. Find out the usage of your personal information, along with information on 5 PRIVACY POLICY MSL EDGE EUROPE LTD what personal information we use, the reasons why we use it, how long those records are kept in the data base, who we share it with, and whether this data has been object of any automated decision making. 

6.3.3. Object to use your personal data when we use it for our legitimate interests, however doing so may have an impact on the services and products we are providing to you. 

6.3.4. Object to use your personal data for marketing purposes in those scenarios where you have provided us with consent. This includes the marketing emails where you can withdraw your consent by clicking in the “unsubscribe” link in any marketing email you will receive. 

6.3.5. Obtain a transferable copy of certain data which can be transferred to another provider. Please note this right applies only under certain circumstances. 

6.3.6. Object to use and/or require to delete your personal data where this is no longer necessary for us to use it. Please note we wont be able to permit this objection where the regulation requires us to maintain the data or share the data details. 

6.4. Please note all the above rights are subject to exemptions and may not apply in all circumstances, and the objection to use the data may cause the suspension of the provision of our products and services to you. 

6.5. You can contact us in dpo@themsl.com for any query and/or complaints, and we are obliged to respond to you without undue delays. If, by any reason, we are unable to deal with your request within a calendar month (due complexity or number of requests that you have made) we may extend this period by a further two calendar months. Should this be necessary we would explain to you the reason of the extension. 

6.6. We will provide all the relevant information electronically as the preferred contact method. 

6.7. We will not charge any fee for responding any request from you to exercise your privacy rights and MSL will try with the best endeavors to respond to your request following our obligations under data protection regulation. 

7. WHO WE MIGHT SHARE YOUR INFORMATION WITH 

7.1. We will share your personal information where: 

7.1.1. We are legally obliged to do so (under any law or regulation); and/or; 6 PRIVACY POLICY MSL EDGE EUROPE LTD 

7.1.2. We are under a duty to comply with any legal obligation as part of our checks to prevent fraud financial crime, or money laundering. This includes sharing with fraud prevention agencies and other organizations which may use the information to prevent fraud and money laundering. 

7.2. We might share your information with other companies within the MSL Group, or with any third party as part of the sale of some business areas, or the whole business, or any business restructure or reorganization. 

7.3. We may store or transfer personal information outside the EEA or EU for processing purposes, always making sure that robust procedures and safeguarding measures are applied to secure, encrypt and maintain the integrity of your personal data. 

7.4. When we use third party service providers, we only disclose to them any personal information that is strictly necessary for them to provide their service. We will always ensure that we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions. 

7.5. Where third parties operate internationally, we will take steps to ensure that any transfer of your personal data outside of the European Economic Area (EEA) is managed carefully in accordance with applicable data protection law. We rely on Standard Contractual Clauses and, where necessary, have identified additional supplementary measures and safeguards to ensure your personal data is given an equivalent level of protection as provided for under the General Data Protection Regulations (GDPR). 

7.6. We complete continual reviews of the countries with sufficient adequacy decisions, standard data protection clauses or approved codes of conduct to ensure your personal data is protected. 

7.7. We carry out due diligence checks with all recipients of your personal data to assess and verify that they have appropriate safeguards in place to protect your information. 

7.8. We ensure that you have enforceable rights and effective legal remedies. 

8. KEEPING YOUR INFORMATION SAFE AND SECURE 

8.1. Once we have received your personal data, we will do our best to protect your personal data. We implement technical and organizational measures to keep your information safe whilst it is in our possession such as: 

8.1.1. Use strict procedures and security features to prevent unauthorized 7 PRIVACY POLICY MSL EDGE EUROPE LTD access.

8.1.2. Ensure that the information we hold about you is stored securely, using encrypted methods where appropriate. 

8.1.3. Implement controls to ensure only appropriate, relevant and necessary personnel can access to your personal data. 

9. CHANGES TO OUR PRIVACY POLICY 

9.1. This Privacy Policy can be updated by time to time. Changes to the Privacy Policy will be updated in this website, and where appropriated via our partners. In case this Privacy Policy is relevant for yourself please regularly check the website to view any updates made. 

10. COOKIES 

10.1. Please click here to refer to our Cookie Policy for more information on how MSL uses the Cookies. 

11. CONTACT 

11.1. All questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo@themsl.com.