I. Introduction

Your privacy is important to the 1Money Network (“we,” “us,” “our”). We are committed to protecting the personal information of our customers and users of our platform, mobile application, and website, as applicable. This Privacy Policy explains how we collect, use, share, and protect your personal data when you use our services (“Services”), such as when you:

When we say "you", we mean you or any individual whose personal information you provide, whether it’s those who explore our Services or those who sign up for and access our Services. Before you provide information about an individual connected to your business to us, you must make sure that you have a lawful purpose or the agreement of the relevant individual. You must also make sure they’ve been provided with this notice, which explains the way in which their information will be processed and their rights in relation to their information.

When we refer to using personal information we refer to collecting, obtaining, recording, holding, storing, organising, adapting, altering, retrieving, transferring, consulting, disclosing, disseminating or otherwise making available, combining, blocking, erasing or destroying your personal information.

This Privacy Policy does not apply to any processing which the 1Money Network carries out as a processor on behalf of those users and Developers who explore and may use the 1Money Network. Please note that we do not control websites, applications, or services operated by third parties, and we are not responsible for their actions. We encourage you to review the privacy policies of the other websites, decentralized applications, and services you use to access or interact with our Services.

Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. By accessing or using Our Website, and Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of Our Website and Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

II. Scope of the Privacy Policy

This Privacy Policy applies to all users of our platform, mobile application, and website, as such services may be available from time to time. We also explain how we collect, use, store, and share personal data and business information in compliance with applicable laws.

III. Information We Collect

1. Categories of Information Collected

Personal Information Provided by You. We collect various types of personal information when you interact with our Services. This includes, but is not limited to:

Information You Provide If You Make Use of, or Interact With, our Services as applicable.

Application Data. If you use our application(s) (as available from time to time in our sole discretion), we also may collect the following information if you choose to provide us with access or permission:

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected. Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

As you navigate through and interact with our Website and use our Services, We, our service providers and third-party sources may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

The information we collect automatically may include personal information. We may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website, Services, and to deliver a better and more personalized service, estimate our audience size and usage patterns, serve you targeted ads and recognize you when you return to our Website.

2. How We Collect Information

We collect data in several ways:

IV. How We Use Information

1. Primary Uses

We use your personal information for a variety of reasons, depending on how you interact with our Services or Website, including but not limited to:

2. Legal and Regulatory Compliance

We use your information to comply with legal obligations, including:

3. Marketing Communications

We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. We may send you communications regarding product updates, new services, or relevant business offerings. You may opt-out of receiving these communications at any time by contacting us or using the unsubscribe option in the email. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

4. Cookies and Performance Optimization

We use aggregated and anonymized data to:

V. What Legal Basis Do We Rely On To Process Your Information?

We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (“GDPR”) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

VI. Cookies and Tracking Technologies

We use cookies and similar technologies (like web beacons and pixels) to gather information about your interaction with our Website and Services. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.The types of cookies we use include:

Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

You can control or disable cookies through your browser settings, but please note that disabling some cookies may limit the functionality of our platform or services.

VII. Information Sharing

We do not sell your personal data. However, we share information with third parties only when necessary.  We may disclose personal information that we collect or you provide as described in this Privacy Policy to the following categories of third parties for the reasons described below:

VIII. International Transfers of Data

We may transfer, store, and process your information in countries other than your own. Our servers are located in the United States (“U.S.”). If you are accessing our Services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in and other countries.  Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Website. By providing any information, including personal information, on or to the Website, you consent to that transfer, storage, and processing.

Solely to the extent applicable, if we transfer your data outside the U.S. to countries with different data protection laws, we ensure appropriate safeguards are in place. For users located in the European Economic Area (“EEA”), United Kingdom (“UK”), or Switzerland, we use measures such as:

For users located in Bermuda, we assess the level of protection afforded by the overseas third party.  Where the level of protection is comparable or better than that provided for under the Bermuda Personal Information Protection Act 2016 (“PIPA”) , we will proceed to transfer the personal information to the overseas third party. Where the level of protection afforded by the overseas third party is not comparable, we will enter into a contract with the overseas third party, requiring compliance with the provisions of PIPA. We may transfer information to overseas third parties certified under the Asia Pacific Economic Cooperation Cross Border Privacy Rules, a certification mechanism for transfers of personal information to overseas third parties approved by the Privacy Commissioner for Bermuda, or any other certification mechanisms recognized by the Privacy Commissioner for Bermuda.

IX. Data Protection for Customers in the EEA, UK, Switzerland, and Bermuda.

For individuals in the EEA, UK, and Switzerland, we comply with GDPR, the UK Data Protection Act 2018, and the Swiss Federal Act on Data Protection. You have the following rights:

To exercise any of these rights, please contact us via the details in Section XIV. If you feel that we have not adequately addressed your concerns, you have the right to file a complaint with your local data protection authority.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at privacy@1moneynetwork.com.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us at privacy@1moneynetwork.com. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Notice to European Users

The information provided in this Privacy Policy applies only to individuals in the EEA, Switzerland, and the UK (collectively, “Europe”).

Personal Information. References to “personal information” in this Privacy Policy is equivalent to “personal information” governed by European data protection legislation.

Controller. We are the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

Processor. We are a processor with regard to personal information processed on behalf of our business customers. If you have concerns regarding personal information that we process on behalf of a business, please review their Privacy Policy and direct your concerns to that business.

Legal bases for processing. We rely on the following legal bases for processing your data described in this Privacy Policy:

We may transfer your personal information to the U.S., to any affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage.  By using our Website or Services or providing any personal information for any of the purposes stated above, you consent to the transfer and storage of your personal information, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such personal information on U.S. servers.

Transfers from other countries. When we transfer personal information outside countries other than those in the EEA, the UK, and Switzerland, we strive to comply with the cross-border data transfer rules of those countries, such as by cooperating with that country’s data protection authority or providing a written agreement to each customer that meets the data protection requirements of the country.

Notice to Bermuda Users

Individuals in Bermuda are entitled under PIPA:

There are circumstances where we have a right to refuse to provide these rights, in which case the individual will be informed.  Otherwise, we will endeavour to comply with any request within 45 days of receiving the request in writing.

X. State Privacy Rights

What Categories of Personal Information do we Collect?

We’ve collected and disclosed the below categories for personal information to create, develop, operate, deliver, and improve our Services, to communicate with you, to ensure the safety, security and integrity of our Services, and for the business and commercial purposes outlined in “IV. How We Use Information” and “VII. Information Sharing,” respectively. We do not collect, use, or disclose sensitive personal information for purposes other than those specified in this privacy policy, to provide the Services, or as permitted under applicable law.

We have collected the following categories of personal information in the past twelve (12) months:

Category

Examples

Collectioned

Indetifiers

Basic User Information, Supplemental Identification Information, Electronic Identification Information

Yes

Commercial information

Transaction Information

Yes

Internet or other similar network activity

Product Usage Information App, browser, and device information, Information from cookies and similar technologies

Yes

Geolocation data

App, browser, and device information

Yes

Audio, electronic, visual, thermal, olfactory, or similar information

Call and video recordings Communications

Yes

Professional or employment-related information

Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

No

Inferences drawn from collected personal information

Information derived from other information about you, which could include your preferences, interests, and other information used to personalize your experience or provide you Services

Yes

Sensitive personal Information

No

We may also collect other personal information outside of these categories through instances where you interact with us online in the context of:

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Access. You can request a copy of the personal information that we have collected about you during the past 12 months.

Deletion. You can ask us to delete the personal information that we have collected from you.

Correction. You can ask us to correct inaccurate personal information that we have collected about you.

Opt-out. You can request to opt-out of disclosures of your personal information that constitute “selling” or “sharing” of your personal information as defined in the CCPA.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Exercising your right to information, access, correction, opt-out and deletion. You may submit requests to exercise these rights via email to privacy@1moneynetwork.com.

Notice of right to opt-out of the “selling” or “sharing” of your personal information. We do not sell your personal information. However, like many companies, we use services that help deliver interest-based ads to you. Our use of some of these services may be classified under California law as “sharing” your personal information (including your business and personal contact information, device data, and online activity data described in the Information We Collect” section above) with the advertising partners that provide the services.

Verification of identity; authorized agents.

We may use information we already have on you to identify you before acknowledging your request. You may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us at privacy@1moneynetwork.com. 

We comply with privacy requirements across the U.S.  Below are rights of residents of certain states, which is not meant to be exhaustive:

California

For customers located in California, we comply with the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). California residents have the following rights:

To exercise your rights, contact us through the details in Section XIV. We will respond within the timelines required by the CCPA/CPRA.

Colorado

For customers located in Colorado, we comply with the Colorado Privacy Act (“CPA”). Colorado residents have the following rights:

Illinois

In Illinois, we comply with Illinois’ Personal Information Protection Act (“ILPIPA”). Illinois residents have rights that include:

New Jersey

For customers in New Jersey, we observe the New Jersey Data Protection Act (“NJCPA”). New Jersey residents have rights such as:

Virginia

For customers in Virginia, we adhere to the Virginia Consumer Data Protection Act (“VCDPA”). Virginia residents are entitled to:

XI. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. Specifically:

XII. Do We Collect Information From Minors?

We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@1moneynetwork.com

XIII. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of significant changes via email or through our platform. The latest version of this Privacy Policy will be posted on our website.

XIV. Questions About This Privacy Policy

If you have any questions, concerns, or requests regarding this Privacy Policy or your data protection rights, please contact us:

1Money Network Technologies Ltd.
Address: 55 Par-la-Ville Road, Hamilton, HM 11, Bermuda
Email: privacy@1moneynetwork.com