Application Privacy Policy

1. ABOUT US AND THIS POLICY

Belmoney is a company operating in the remittances business, headquartered in Belgium, and conducting transactions with countries worldwide. Collaborating with various partners, our sole objective is to streamline your transactions and simplify your life.

This policy extends to all platforms utilized by Belmoney, whether web-based or application-based. Alongside this policy, Belmoney has established a comprehensive and meticulously structured compliance framework to safeguard the interests of both the company and its customers. Consequently, any additional concerns not addressed within this document should be referred to the relevant sections of the compliance documents.

2. THE DATA WE COLLECT

The data Belmoney collects from its customers depends on the interaction type and the product the customer intends to use. Additionally, it must be stated that when a referring to "personal data" or "personal information" is made, it means that any information pertaining to an individual.

This Policy also depicts, as shown below, the types of information Belmoney collects from its customers:

Basic Identifying Information: This type of information could include full name, postal address, email address, phone number, date of birth, gender and profession. Additionally, social username or similar identifiers can be asked.

Customer Support Information: The information provided by the customer contacting the customer services, e.g. including call recordings.

Government Issued Identification or Records: This type of document can be exemplified as driver's license, passport, military, visas or national cards. Conversely, it also can be deemed as the Selfie ID procedure adopted by Belmoney where the customer is obliged to provide a recording with his identification document next to his face to prove the similarity. Furthermore, documentation such as Proof of Address or utility bill also are encompassed by this category.

Marketing & Communications Information: Concerning marketing collected data, it can be characterized as the customers preferences for receiving marketing communications from Belmoney and our third parties, communication preferences, and information lawfully obtained from market research, advertising networks, or analytics providers.

Payment Information: Payment Information covers the customer's financial or payment instrument details, such as debit and credit card, or bank account details.

Promotions & Competitions Information: Belmoney, when conducting promotions or competitions, will utilize your name, email and any other personal information required for participation for such events.

Beneficiary Information: This topic encompasses the beneficiary's full name, postal address, phone number, and depending on the disbursement method selected, certain financial institution or account details such as bank account or mobile wallet account.

Referral Information: Information provided by the customer about the beneficiary, such as name and email address, to introduce them to our services.

Sensitive Personal Data: Sensitive Personal Data can be deemed as the biometric data, particularly face scan information from photos and videos provided for identity verification purposes, and monitoring of login activity and interactions with our site to safeguard the customer's account and identify suspicious or fraudulent activity.

Survey & Feedback Information: Survey and feedback information includes the customer's name, email address, or other contact information, along with responses to surveys, reviews, feedback, testimonials, and any other personal information requested.

Technical Information: This comprises details about the hardware and software Belmoney's customers use to access our services, network information, internet service provider, operating system, browser type, unique device identifiers, IP address, other similar unique identifiers, and your current location, using GPS technology.

Transaction Information: Belmoney keeps the customers history/logs, transaction receipts, purpose of transfers, relationship with the beneficiary, average transaction amount, frequency of use of our services, intention to send to multiple recipients, and referral rewards.

Usage Information: This includes details of the customers interactions with Belmoney's services or sites, as well as browsing or search activity.

3. BELMONEY COLLECTING DATA

Belmoney collects personal data directly from the customer when the customer engages with Belmoney's services, including creating a profile, contacting the Company via chat, participating in surveys, interacting at events, entering sweepstakes or promotions, posting reviews, or subscribing to receive emails, text messages, or postal mailings.

Additionally, when the customer visits Belmoney's websites, uses its app, opens or clicks on emails, or engages with Belmoney's advertisements, Belmoney or Belmoney's third-party partners automatically gather certain information through technologies such as cookies, web beacons, and pixels.

Furthermore, Belmoney may obtain data about the customer from external sources, including data analytics providers, marketing or advertising services, social media platforms, fraud prevention services, credit reporting agencies, vendors providing services on Belmoney's behalf, or publicly available sources. For more information, please refer to Belmoney's Cookie Policy.

4. BELMONEY PROCESSING DATA

Belmoney will only use the customer's personal data when the law allows it. Depending on the country in which the customer is located, Belmoney relies on the following legal bases to process personal data:

                Compliance with Legal Obligations: Belmoney uses personal data to comply with legal or regulatory obligations, to establish or exercise rights, and to defend against legal claims. This includes security and fraud prevention measures to detect, investigate, prevent, or take action regarding malicious, deceptive, fraudulent, or illegal activity.
            

                Performance of a Contract: Belmoney uses personal data to provide services, process transactions, maintain accounts, and communicate with customers regarding requests, inquiries, issues, or feedback.
            

                Consent or Legitimate Interest: Belmoney uses personal data for marketing and promotional purposes, analytics and personalization, and other business or commercial purposes with the customer's consent or legitimate interest.
            

4.1 Belmoney Processing Sensitive Data

Belmoney may request specific consent from the customer for the collection, use, and storage of biometric data during the verification process, as required by privacy regulations in the customer's jurisdiction. If consent is not provided, alternative methods for identity verification may be offered, though these may take longer. Belmoney will not disclose or share any biometric data with anyone other than its identity verification providers, unless required by applicable laws and regulations or pursuant to a valid court order.

5. BELMONEY SHARING DATA

In addition to the specific situations discussed elsewhere in this privacy policy, Belmoney discloses personal data in the following circumstances:

Corporate Affiliates

Personal data may be shared with Belmoney's corporate affiliates, including its parent company, affiliates, and subsidiaries. These affiliates process personal data on Belmoney's behalf to provide services or with the customer's consent or as permitted or required by law.

Service Providers

Certain personal data is shared with third parties that support Belmoney's core business functions and internal operations. This includes banks, disbursement providers, financial institutions processing transfers, identity verification or KYC service providers, and third parties providing software tools for communication, marketing assistance, fraud investigation, customer surveys, and customer service outsourcing.

Third-Party Partners

Personal data may be shared with third parties with whom Belmoney has partnered to create and offer products, services, or joint promotions. Additionally, personal data may be shared with banking or distribution partners in case of suspected violations of terms or fraudulent behavior.

Social Media Platforms and Networks

Some of Belmoney's websites feature plugins, widgets, or tools provided by third parties, resulting in the collection or sharing of information between Belmoney and the third party. Their use of the customer's information is governed by their respective privacy policies.

Business Transactions

In the event of a merger, corporate transaction, or transfer of business assets, customer information may be shared with involved business entities or individuals.

Legal Process

Belmoney may disclose personal data in response to subpoenas, court orders, government inquiries, or to comply with laws and regulations. This includes disclosures to establish, exercise, or protect rights; defend against legal claims; ensure visitor safety and security; detect and prevent fraud; and address illegal activities or policy violations.

Other Instances

Belmoney may inquire if the customer would like their information shared with other third parties not described elsewhere in this policy.

6. CUSTOMER'S RIGHTS

Belmoney's customers in certain regions of the world are entitled to specific data privacy rights under applicable privacy legislation, including but not limited to the laws of the Kingdom of Belgium. Belmoney endeavors to implement the best privacy practices as a standard for all customers. These rights include:

Access Your Data & Data Portability

Customers may request a copy of their personal data held by Belmoney, provided without undue delay, subject to certain exceptions or limitations.

Correct Your Data / Data Rectification

Customers have the right to request updates and corrections to inaccuracies in their personal data. They can update certain information related to their account by logging in or contacting Belmoney.

Data Deletion / Erasure

Customers may request the erasure of their personal data, subject to applicable law. If an account is closed, certain information will be retained for a period to deter fraud and comply with legal obligations.

Restrict Processing of Data Requests

Customers have the right to request restrictions or object to the processing or transfer of their personal data under certain circumstances.

Unsubscribe from Direct Marketing

Customers have the right to opt-out of processing their personal information for marketing purposes at any time. They can exercise this right by clicking on the 'unsubscribe' link in promotional emails.

Automated Individual Decision-Making, Including Profiling

In some jurisdictions, customers have the right not to be subject to decisions based solely on automated processing of personal data. Exceptions may apply under relevant data protection laws.

Withdraw Your Consent

Customers have the right to withdraw consent for Belmoney to process their data, where lawful processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

How to Exercise Your Rights

To exercise these privacy rights, customers can submit a request via email to enquiry@belmoney.be or contact Belmoney via chat or phone. Identity verification may be required for processing certain requests, and customers may be contacted by phone or email for verification purposes.

7. HOW BELMONEY PROTECT THE CUSTOMERS DATA

Belmoney employs industry-accepted standards to protect the information customers submit. Data encryption technology is implemented to safeguard sensitive data such as bank account numbers, credit card numbers, dates of birth, and government identification numbers transmitted through the site and/or app.

Additionally, security credentials, like usernames and passwords, are required for accessing information on the site and/or app. Customers are responsible for maintaining the confidentiality and security of their security credentials.

If access to Belmoney's services is allowed via fingerprint on a device (e.g., Apple Touch ID), customers should not register any other person's fingerprint on that device to prevent unauthorized access. While efforts are made to ensure security, no method of transmission over the Internet or electronic storage is 100% secure.

Therefore, Belmoney cannot guarantee absolute security, and any transmission of personal information is at the customer's own risk. For security-related inquiries, customers can contact Belmoney at: enquiry@bel.money

8. BELMONEY'S DATA RETENTION

Belmoney will retain customer personal data only for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements. To determine the appropriate retention period, considerations are made based on the customer's country of residence, among other factors:

Legal and regulatory obligations or retention periods imposed by applicable laws and regulators
The quantity, nature, and sensitivity of the personal data
Potential risks of unauthorized use or disclosure of personal data
Purposes for processing personal data and alternative means to achieve those purposes

                IMPORTANT: As a regulated financial institution, Belmoney is mandated by law to retain certain personal and transactional data even after account closure. Customers explicitly agree to Belmoney retaining their personal data, including transaction-related and identity verification data, for at least 10 years following the termination of the legal relationship.
            

9. CHANGES OF THIS POLICY

Belmoney reserves the right to amend this Policy at any time, and any changes will be communicated by posting a revised version on our Site and App. The Company encourages the customer to review this Policy each time he is engaging in a transaction, as it may have been updated since the customer's initial registration or last transaction. If the customers disagree with any aspect of this Policy or any changes made, he has the option to terminate your agreement with Belmoney and close his profile by emailing Belmoney at: compliance@belmoney.be

10. CONTACT AND COMPLAIN

If you have any questions, concerns, or complaints regarding the processing of your personal data, you may contact us at:

                Belmoney S.A.

                Avenue Louise, 54

                1050 Ixelles, Belgium

                Email: enquiry@bel.money

                Phone: +32 2 880 24 90

We will address your concerns promptly and in compliance with applicable legal requirements. If you are not satisfied with our response, you have the right to lodge a complaint with the Belgian Data Protection Authority:

Belgian Data Protection Authority

Address: Rue de la Presse 35, 1000 Brussels, Belgium

Email: contact@apd-gba.be

Phone: +32 (0)2 274 48 00

11. LEGAL BASIS

We process your personal data based on one or more of the following legal grounds, as defined by the General Data Protection Regulation:

a) Contractual Necessity

Processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract.

b) Legal Obligation

Processing is necessary for compliance with a legal obligation to which we are subject as a financial institution.

c) Legitimate Interests

Processing is necessary for the purposes of our legitimate interests, provided these are not overridden by your interests or fundamental rights and freedoms.

d) Consent

Where you have provided explicit consent for specific processing activities in the context of financial services and marketing, you may withdraw your consent at any time by contacting us.

Data Privacy Policy