PRIVACY POLICY

Moonable OÜ (“Company”, “Moonable”) respects your privacy and complies with the General Data Protection Regulation (Regulation (EU) 2016/679), alongside with the Personal Data Protection Act (Estonia), on the protection of natural persons with regard to the processing of their personal data.

This Privacy Policy explains the types of personal data we may collect on you, how we store and handle that data and your rights in that regard.

This Privacy Policy regulates privacy practices (collection, use and disclosure) as to your personal information during your use of the Company Services.

This Privacy Policy should be read together with the E-MONEY​ & PAYMENT ​SERVICES​​ TERMS OF USE (“Terms”), constitutes a legal agreement between the Company and the e-money holder and/or payment services user (“You”), shall be an integral part thereof, and shall be legally binding for both parties. If you disagree with this Privacy Policy, please do not use our Services.

The Privacy Policy together with the Terms shall be deemed accepted by You upon Your clicking the respective box “I have read and agree to the Terms”. The terms used in this Privacy Policy shall be understood in accordance with the Terms and the applicable law.

You are legally deemed as having full capacity, are of sound mind and are at least 18 years old, as stipulated in the Terms, too.

1. DATA CONTROLLER

1.1. The Company is the Controller responsible for your personal data collection and processing. The Company has appointed the Data Protection Officer, who can be contacted by e-mail[email protected]

2. WHAT IS COLLECTED

2.1. The Company collects information from and about You: directly from You when You provide it to us, as well as automatically when You use our Services in cases as stated below.

2.2. The Company shall be entitled to collect, store and use the following personal data/information:

•     contact details, such as name (corporate name and identification number – for legal entities), address, telephone number, email address;
•     financial and transaction data, such as credit or debit card number, and bank account information; name of the recipient and provider if applicable; and
•     any other information, which is provided by You in order for the Company to provide the Services, including information that concerns all the operations conducted through Moonable, which does not allow to directly identify You.

2.3. When You use our Services, we may automatically receive such information:

•     the data of the browser used, the type and version of the operating system;
•     the type of the device used and its screen resolution;
•     the used IP address(es);
•     the time and date of visiting our website;
•     other data the use of which is necessary for the operation of Moonable and its improvement.

3. THE LEGAL BASIS

3.1. The legal basis for personal data collection and processing shall be as follows:

•     Consent – the basis that arises upon Your explicit agreement to processing Your personal data for a specific purpose, e.g., acceptance of Cookies, registration of Your Moonable Account, execution of transactions, receipt of notifications, etc;
•     Contract – the basis when Your personal data processing is required under contractual obligations;
•     Legitimate interest – on this basis we may take measures for fraud prevention, for commercial interest, for direct marketing purposes, with Your consent if and where provided, etc. Using the legitimate interest basis, the Company will observe Your fundamental rights and freedoms, to comply with applicable law;
•     Legal obligation – the basis that arises when data processing is required to comply with the law, or as a statutory obligation (not a contractual obligation).

4. USE AND STORAGE OF THE DATA

4.1. The purpose of the collected data/information use and processing is to:

•   provide our Services;
•   verify an identity for compliance purposes (KYC procedures, checks, etc.);
•   monitor, detect, and prevent fraud and other harmful activity (if any);
•   process the payments, as well as communicate regarding the payments;
•   promote, analyze and improve our Services;
•   personalize your access to our website and Services;
•   respond to enquiries, send Service notices and provide customer support;
•   notify You on the usage of our website and Services;
•   analyse errors to improve the operation of our website.
•   conduct audits, for regulatory purposes and compliance with industry standards;
•   develop new products;
•   send marketing communications, etc.

4.2. The Company will store Your personal data subject to the Internet Security framework and safeguards for a reasonable time depending on the nature of the Services or for the time prescribed by the applicable law.

4.3. Provided that the Company informed You and You agreed (hereby including), the Company may use Your data to send You notifications, newsletters, Services and other updates.

4.4. Whenever You give us Your consent to collect, use, store or disclose your personal data, You have the right to withdraw such consent at any time by emailing to us, as indicated in the Contact information.

4.5. If Your personal data changes, You can update or correct it in Your Moonable Account or by emailing to us.

4.6. If You terminate Your Moonable Account, the Company will remove Your personal data. However, please note:

• there is a possibility of delays in removal of Your data from our servers;
• the information may be saved if it is necessary to fulfil our legal and financial obligations, dispute resolution, or for the fulfilment of our contracts.

5. DISCLOSURE OF INFORMATION

5.1. The Company will not disclose information to the third parties, however the Company is entitled to transfer the personal data of the clients/users in whole or in part, including but not limited to, the third parties, even those located outside Estonia, such as (where applicable):

• the Company’s subsidiaries or affiliates;
• persons, who require such information to complete the initiated transfer (e.g., business partners/providers);
• persons responsible for financial monitoring;
• to other persons, if this is required by the Terms or under the applicable law.

5.2. By no means shall the Company disclose Your personal data to other persons or in other ways than specified in this Privacy Policy, other than with Your prior consent.

6. YOUR DATA PROTECTION RIGHTS

6.1. You have the following data protection rights:

•     right to access – You have the right to ask us about an access to Your personal data by providing You with copies of Your data;
•     right to rectify – if You find Your data inaccurate or incomplete, You have the right to ask us to rectify or complete it;
•     right to erase – You have the right to erase Your data and ask us Your personal information to be deleted completely;
•     right to restrict – You have the right to ask us to restrict the processing of Your data regarding the way we do it;
•     right to object – You have the right to object to processing of Your data, if no enquiry from You is in progress, or we no longer need Your data, or You initially consented to Your data use, but have now withdrawn Your consent, and/or we are not restricted by law to do so;
•     right to data portability – You also have the right to the portability of data You provided to us and You have the right to ask us to transfer, move, copy Your information, or give it to You;
•     withdrawal of consent – You have the right to withdraw Your consent to process Your personal data any time, without affecting the lawfulness of processing based on consent before such consent withdrawal;
•     right to lodge a complaint – You can contact us for a complaint if You are not satisfied with our handling of Your personal data. If You still remain not satisfied, You can lodge a complaint with the Estonian Data Protection Inspectorate on the website https://www.aki.ee/

6.2. You have the right to unsubscribe from our mailings, e-newsletters, marketing notifications, at any time, whether with regard to initial or further processing, by e-mail: [email protected]

6.3. You are not required to pay any charge for exercising Your rights.

6.4. We have up to 1 month to respond to You.

7. COOKIES POLICY

7.1. Cookies are small data files sent to your device (computer, tablet or mobile phone) from a website and stored on your device’s hard drive.

7.2. The Company can use Cookies, such as:

•     Necessary Cookies that allow you to use our Services (e.g., cookies for authentication on the website, cookies for ensuring security to detect the violation of the authenticity of the website, security, accessibility, network management, etc.);
•     Effective Cookies for collecting information about using our website;
•     Functional Cookies that give an opportunity to save the interface settings selected by You (e.g., the selected language or region, the font size, the appearance of the web page, to customize elements, to remember your preferences, etc.);
•     Advertising Cookies that give an opportunity to provide advertising content in accordance to Your interests, where applicable.

7.3. You can set your browser to accept or refuse Cookies, as well as to remove or change the settings of Cookies. For further information on how to manage Cookies, please visit https://www.allaboutcookies.org/

8. LINKS TO THIRD-PARTY WEBSITES

8.1. Moonable may contain links to third-parties’ websites. The privacy policy and cookies policy on such third parties’ websites may differ from our policies, being out of our control and responsibility. We encourage You to read carefully these policies on such websites before using them or providing them with any information, including Your personal data.

8.2. In any case, it is Your sole responsibility to familiarize with the privacy and cookies practices of other websites and parties.

9. SECURITY

9.1. The Company takes a wide range of reasonable measures (organizational, technical, administrative etc.) to protect Your personal data within provision of the Services from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction.

9.2. In case You have reasons to think that Your interaction with the Company might be no longer secure, You have to contact us immediately. When appropriate, the Company shall notify whose data may have been compromised and to take other steps in accordance with the applicable law.

10. DISCLAIMERS AND LIABILITY AS TO PRIVACY

10.1. Only authorized Company’s employees shall have access to Your personal data. Such employees undertake duty to strictly observe the confidentiality and prevent unauthorized access of third parties to Your personal and other data.

10.2. Despite the measures taken to protect Your personal data, the Company warns that no data transmission or storage system can be guaranteed to be wholly and totally secure, even if the Company improves the safety of the personal data.

10.3. The Company cannot and will not be responsible for the consequences of Your voluntary sharing or distribution of any of Your personal data or the personal data of the other clients somewhere within the Services provided by the Company.

10.4. The Company shall not be responsible for any acts of the third persons (including hackers, intruders, and other violators) in relation to Your personal data both within and beyond the Services provided by the Company irrespective of whether the data was received during the Services provision or otherwise. The Company shall not be responsible for any illegal acts of the third parties who may breach the provisions of this Privacy Policy.

10.5. When registering Your Moonable Account, You confirm that You provide true and accurate information. If You provide false or inaccurate data or the Company has reasonable and sufficient grounds to suppose that such information is false or inaccurate, the Company is entitled not to provide its Services, and block Your Moonable Account on a temporary basis (till all the disputable matters are settled) or for an indefinite period of time, as provided by the Terms, too.

11. GOVERNING LAW

11.1. This Privacy Policy and other relationships between the parties are governed by the law of Estonia.

12. AMENDMENTS

12.1. This Privacy Policy may be amended, including any material change, at any time. Any amendments or additions to this Privacy Policy shall be valid only after a new version of the Policy is placed at our website. The new version of the Privacy Policy shall come into force at the moment it is placed at our website, unless otherwise provided for by the new version of the Privacy Policy.

12.2. The date the Privacy Policy was last updated is identified at the top of the page. You are responsible for ensuring that the Company has Your up-to-date, active and deliverable email address, and for periodically visiting this Privacy Policy to check for any changes.

13. CONTACT INFORMATION

If You have any questions about this Privacy Policy, please contact us by email: [email protected]