MONEYGOLD PRIVACY STATEMENT AND COOKIE POLICY

Moneygold Company (“Moneygold”, “we”) process personal data of visitors of the website https://money-gold.co.uk/ (“Website”).

Our Privacy Statement explains, for example, the types of personal data we process, how we process the personal data and how you may exercise your rights as a data subject (e.g. right to object, right of access).

This Privacy Statement may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on the Website. We will not make substantial changes to this Privacy Statement or reduce the rights of the Users under this Privacy Statement without providing a notice thereof.

1. DEFINITIONS
1.1. “Moneygold Services” refers jointly to the Website and the Moneygold App.
1.2. “User” or “you” refers jointly to our customers, representatives and other authorized users, potential customers and the users of the Moneygold Services.
1.3. “Moneygold Company” means MONEYGOLD INTERNATIONAL GROUP LIMITED, a merchant company that acts as a platform that serves orders and their payment on the Website.

2. DATA CONTROLLER
This Privacy Statement applies to processing of personal data carried out by Moneygold Company. The English company, Moneygold International Group Limited, is the controller of the personal data you submit to us and responsible for your personal data under applicable data protection law.

3. CATEGORIES OF PERSONAL DATA PROCESSED
3.1. The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.
3.2. User Data is personal data collected directly from you, as the case may be. We may collect User Data from our Users in a variety of ways, including when Users register to the Moneygold Services, order service, subscribe to a newsletter or fill out a form. Further, please note that we also collect details of any transactions and payments you carry out through the Moneygold Services.
3.3. User Data that is necessary in order to use the Moneygold Services.
3.4. The following personal data collected and processed by us is necessary in order for a proper performance of the contract between you and us as well as for the compliance with our legal obligations, when you register to the Moneygold Services and create a user account or make an order:
3.4.1. name (first name or last name)
3.4.2. telephone number
3.4.3. full delivery street address including city, state and postcode
3.5. Your user or customer experience may be enhanced by providing us with the following Additional Account information:
3.5.1. email address
3.5.2. location data (if you consent to the processing of your location data)
3.5.3. birthdate
3.5.4. information relating to your payment instrument(s) such as the number of your payment instrument(s) and the expiration date of your payment instrument(s) (not stored by Moneygold, since Moneygold uses a third party payment service provider for processing
of payments)
3.5.5. other information you provide either when creating a user account or later when modifying your account profile
3.6. Other Information. We may also process other information provided by you voluntarily such as but not limited to:
3.6.1. information you provide when rating our services
3.6.2. marketing opt-ins and opt-outs
3.7. In addition to User Data collected from you, we process certain personal data we get from technical sources.
3.8. Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
3.9. We may automatically collect the following Analytics Data when you visit or interact with the Moneygold Services:
3.10. Device Information. We collect the following information relating to the technical device you use when using the Moneygold Services:
3.10.1. device and device identification number, device IMEI
3.10.2. country
3.10.3. IP address
3.10.4. browser type and version
3.10.5. operating system
3.10.6. Internet service providers
3.10.7. advertising identifier of your device
3.10.8. visitor identifier
3.11. Usage Information. We collect information on your use of the Moneygold, such as:
3.11.1. information about your orders made on the Moneygold Services, time spent on the Moneygold Services
3.11.2. information on your orders made through the Moneygold Services
3.11.3. the URL of the website you visited before and after visiting the Moneygold Services
3.11.4. the time and date of your visits to the Moneygold Services
3.11.5. the sections of the Moneygold Services you visited
3.11.6. the products you searched for while using the Moneygold Services
3.12. Cookies. We use various technologies to collect and store Analytics Data and other information when the Users visit the Moneygold Services, including cookies and web beacons.
3.12.1. Cookies are small text files sent and saved on your device that allows us to identify visitors of the Moneygold Services and facilitate the use of the Moneygold Services and to create aggregate information of our visitors. This helps us to improve the Moneygold Services and better serve our Users. The cookies will not harm your device or files. We use cookies to tailor the Moneygold Services and the information we provide in accordance with the individual interests of our Users.
3.12.2. The Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent.
3.12.3. Please note that some parts of the Moneygold Services may not function properly if use of cookies is refused.
3.12.4. A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been
read.
3.13. Web analytics services. The Moneygold Services use the services mentioned below to compile Analytics Data and reports on visitor usage and to help us improve the Moneygold Services such as:
3.13.1. Google Analytics https://analytics.google.com (including Google Tag Manager https://tagmanager.google.com , Google Marketing Platform https://marketingplatform.google.com , Google Ads https://ads.google.com ), as well as
3.13.2. Yandex Metrica https://metrika.yandex.ru ,
3.13.3. Facebook for Business https://www.facebook.com/business/tools/ads-manager.
3.14. For an overview of the services mentioned above, please follow the attached links).
3.15. Advertising and visitor identifiers. The Moneygold Services use pseudonymized identifiers to track and predict your app and service usage and preferences.
3.16. Children’s information. We do not provide services directly to children or proactively collect their personal information.

4. PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR
PERSONAL DATA
4.1. Purposes. There are several purposes of the processing of your personal data by Moneygold:
4.2. To provide the Moneygold Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate
interest)
4.2.1. Moneygold processes your personal data to be able to offer the Moneygold Services to you under the contract between you and Moneygold.
4.2.2. We use the personal data for example to handle your payments or any refunds (where applicable) and to provide our Partners with the information necessary for the preparation or delivery of your order. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.
4.3. For our legal obligations (legal ground: compliance with a legal obligation)
4.3.1. Moneygold processes data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
4.3.2. For claims handling and legal processes (legal ground: legitimate interest)
4.3.3. Moneygold may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
4.4. For customer communication and marketing (legal ground: legitimate interest)
4.4.1. Moneygold processes your personal data to contact you regarding the Moneygold Services and to inform you of changes relating to them.
4.4.2. Your personal data are also used for the purposes of marketing the Moneygold Services to you (when Moneygold sends you emails,
push-notifications and calls you in order to know your opinions about goods and service of Moneygold).
4.5. For quality improvement and trend analysis (legal ground: legitimate interest)
4.5.1. We may also process information about your use of the Moneygold Services to improve the quality of the Moneygold Services e.g. by analyzing any trends in the use of the Moneygold Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.
4.6. Legal grounds for processing
4.6.1. Moneygold processes your personal data to perform our contractual obligations towards you and to comply with legal obligations.
4.6.2. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships.
4.6.3. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.
4.7. In some parts of the Moneygold Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.
5. TRANSFER TO COUNTRIES OUTSIDE THE UK
5.1. We use third-party cloud platform Azure, provided and secured by Microsoft LLC to store the information you provide to us and the information we collect electronically. Access to these computer servers is controlled by firewalls and security gatekeepers.
5.2. However, while transferring your personal data overseas, we rely on the privacy shield framework for any transfers of data to Microsoft data centres. data centres, or Google data centres.
5.3. We do not transfer your personal information outside the European Economic Area.
5.4. We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which they are processed.
5.5. More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses on our website..

6. RECIPIENTS
6.1. We only share your personal data within the organization of Moneygold if and as far as reasonably necessary for the purposes of this Privacy Statement.
6.2. We do not share your personal data with third parties outside of Moneygold’s organization unless one of the following circumstances applies:
6.2.1. For the purposes set out in this Privacy Statement and to authorized service providers:
6.2.1.1. To the extent that third parties (express delivery companies) need access to personal data in order for us to perform the Moneygold Services, we provide such third parties with your personal data. Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, sales and marketing) to
process it for us and to payment service providers to process your payments to us.
6.2.1.2. When data is processed by third parties on behalf of Moneygold, Moneygold has taken the appropriate contractual and
organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy
Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate
obligations of confidentiality and security measures.
6.2.1.3. Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Moneygold
Services, the processing is typically based on their policies and standards.
6.2.2. For legal reasons and legal processes
6.2.2.1. We may share your personal data with third parties outside Moneygold if we have a good-faith belief that access to and
use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Moneygold, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
6.2.3. For other legitimate reasons
6.2.3.1. If Moneygold is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved.
However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the Users concerned
when the personal data are transferred or become subject to a different privacy statement.
6.2.4. With your explicit consent
6.2.4.1. We may share your personal data with third parties outside Moneygold, including those that are located in countries
outside the EU or the UK, when we have your explicit consent to do so that you give us by using Moneygold Services. We,
however, inform you of the possible risks of such transfers for your personal data as we cannot guarantee its safety due to
possible absence of an adequacy decision and appropriate safeguards in such overseas countries. You have the right to
withdraw this consent at all times free of charge by contacting us.

7. STORAGE PERIOD OF PERSONAL DATA
7.1. Moneygold does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Moneygold Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use. Thus, such maximum storage period is limited by the
order completion period.
7.2. Most personal data relating to a User’s user account with the Moneygold Services will be deleted after a period of 24 hours have lapsed after the User has deleted its user account with the Moneygold Services. Thereafter, a part
of the personal data relating to a User’s user account with the Moneygold Services may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes.

8. YOUR RIGHTS
8.1. Right to withdraw consent. In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time free of charge. Withdrawing a consent may lead to fewer possibilities to use the
Moneygold Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. To withdraw the consent the User should write an email to mail@money-gold.ru.
8.2. Right of access. You have the right to access and be informed about your personal data processed by us. We give you the possibility to view certain personal data through your user account with the Moneygold Services or request a copy of your personal data.
8.3. Right to rectify. You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. You can correct or update some of your personal data through your user account in the Moneygold Services.
8.4. Right to erasure. You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data, such as but not limited to:
8.4.1. you have an ongoing matter with Moneygold;
8.4.2. you have an open order which has not yet been shipped or partially shipped
8.4.3. if you have made any purchase, we will keep your personal data in connection to your transaction for book-keeping purposes.
8.5. Right to restriction of processing. You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the Moneygold Services.
8.6. Right to data portability. You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.
8.7. Right to object. You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Moneygold Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Moneygold Services.
8.8. Right to lodge a complaint with a supervisory authority. If you consider that the processing of personal data infringes General Data Protection Regulation (GDPR) or other applicable protection laws, you have the right to lodge a complaint with a supervisory authority, in particular in the Information Commissioner’s Office (https://ico.org.uk/) in the UK, in place of work or place of the alleged infringement.
8.9. How to use your rights. The abovementioned rights may be used by sending us a letter or an e-mail on the addresses set out above, such as mail@money-gold.ru, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject or charge requests that are unreasonably repetitive, excessive or manifestly unfounded.

9. DIRECT MARKETING
The User has the right to prohibit us from using the User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the functionalities of the Moneygold
Services or the unsubscribe possibility offered in connection with any direct marketing messages.

10. INFORMATION SECURITY
10.1. We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Moneygold Services, systems, and other assets for security vulnerabilities.
10.2. Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

last updated: 19/02/2022