Issuing Entity: GLOBENET FOREX LIMITED and its affiliates (collectively referred to as "TxnGo", "We", "Us" or "Our")
Article I: Policy Overview
Section 1.1 Policy Overview
This Privacy Policy sets forth the rules governing the collection, use, storage, sharing and protection of user information by us through our official website and other TxnGo services and products (collectively, "TxnGo Services").
Article II: Personal Data Collected
Section 2.1 Personal Data
Personal data means information that identifies a natural person and does not include anonymized data. We collect and process the following categories of personal data:
(1) Identity Data: name, title, tax identification number, marital status, date of birth, gender, identification document number, nationality, and information contained in identification documents;
(2) Contact Data: billing address, residential address, email address, telephone number, communication records;
(3) Financial Data: bank account information, source of funds, source of wealth, credit history, investment and financial status;
(4) Transaction Data: transaction amount, date, time, payee and other transaction details under TxnGo Services;
(5) Technical Data: IP address, login information, browser type and version, device operating system, time zone, plug-in information, and other technical information regarding devices and networks;
(6) Account Profile Data: username, password, preferences, feedback and survey responses;
(7) Usage Data: information regarding users' conduct in using TxnGo Services;
(8) Marketing and Communications Data: marketing preferences, communication method preferences;
(9) Survey and Feedback Data: questionnaires and feedback information submitted by users;
(10) Location Data: device geolocation information;
(11) Other Necessary Personal Data.
Section 2.2 Aggregated Data
We may collect aggregated data which does not directly or indirectly identify a user and which is not considered personal data. If aggregated data is combined with personal data such that identification becomes possible, it shall be protected as personal data.
Section 2.3 Special Categories of Personal Data Not Collected
We do not collect special categories of personal data, including but not limited to race, ethnicity, religion, philosophical beliefs, political opinions, trade union membership, health information, genetic and biometric data, or information concerning sex life or sexual orientation.
Section 2.4 Criminal Conviction and Legal Proceeding Data
For the purposes of identity verification, fulfilling compliance obligations, and preventing illegal activities and fraud, we may obtain information concerning users' criminal convictions, related litigation and judgments during our compliance review process. Such information will be processed only in accordance with applicable laws.
Section 2.5 Consequences of Failure to Provide Personal Data
If laws or contractual requirements mandate the provision of personal data and a user fails to provide such data, we may be unable to provide TxnGo Services. We shall have the right to close the account or restrict service access in accordance with the user agreement, and shall inform the user in advance.
Article III: Methods of Collecting Personal Data
Section 3.1 Direct Interaction Collection
Users voluntarily provide personal data by filling in forms, sending correspondence via mail, telephone or email, using the Services, making transfers, making investments, undergoing identity verification, subscribing to marketing communications, participating in surveys, engaging with customer service, submitting feedback, and through other direct interactions.
Section 3.2 Automated Technology Collection
We automatically collect usage data and technical data through technologies such as Cookies and server logs. When a user visits a third-party website that hosts our Cookies, we may also obtain technical data, as further detailed in our Cookie Policy.
Section 3.3 Collection from Third Parties and Public Sources
We obtain personal data from data analytics service providers, payment service providers, tax authorities, credit reference agencies, identity verification and compliance service providers.
Section 3.4 Third-Party Personal Information
If a user provides us with personal information of any third party, such user shall have obtained the lawful authorization of such third party.
Article IV: Rules for Use of Personal Data
Section 4.1 Purposes of Collection
We collect personal data for the following purposes: providing the full functionality of TxnGo Services, customer service, service updates and security notifications, identity verification, preventing fraud and unauthorized conduct, fulfilling legal obligations, and achieving other purposes for which the data was collected.
Section 4.2 Combination of Data from Multiple Sources
We may combine data from multiple channels to optimize and personalize TxnGo Services, content and advertising.
Section 4.3 Legal Bases for Processing
We process personal data based on the following legal bases: performance of a contract with the user, compliance with a legal obligation, our legitimate business interests, and user consent. When processing data based on legitimate business interests, we will fully balance such interests against the user's rights.
Section 4.4 Limitation on Use
We will only use personal data for the purposes set forth in this Policy and as permitted by applicable laws. If we need to use personal data for a new, incompatible purpose, we will inform users in advance and specify the legal basis for doing so.
Section 4.5 Third-Party Links
TxnGo Services may contain links to third-party websites, plug-ins and applications. The data collection and processing practices of such third parties are the sole responsibility of such third parties, and users should review the privacy policies of such third parties.
Article V: Sharing of Personal Data
Section 5.1 Parties with Whom We May Share Personal Data
To achieve the purposes set forth in Article IV of this Policy, we have the right to share personal data with the following parties:
(1) banking partners;
(2) investment fund management partners;
(3) identity verification service providers;
(4) operational service providers (data storage, customer service, IT, communications, security and risk control);
(5) data analytics, advertising and marketing service providers;
(6) law enforcement agencies and regulatory authorities;
(7) TxnGo group affiliates;
(8) business partners;
(9) professional advisors (audit, legal, compliance, accounting, etc.);
(10) third-party transferees in transactions such as business mergers and acquisitions or asset transfers;
(11) third parties authorized by the user;
(12) data sub-processors;
(13) artificial intelligence service providers.
Section 5.2 Scope of Sharing
Sharing of personal data is limited to the extent necessary, and third parties shall process personal data as instructed by us.
Article VI: Cross-Border Data Transfers
We conduct our business globally, and personal data may be stored or processed in any country/region where we or our service providers operate.
Article VII: Data Retention Period
Section 7.1 Retention Period
We will retain personal data only for as long as reasonably necessary to achieve the purposes for which it was collected and to satisfy legal, accounting, regulatory and reporting requirements.
Section 7.2 Factors Considered in Determining Retention
The retention period is determined by taking into account the nature and sensitivity of the data, the risk of unauthorized use, the purposes of processing, and legal requirements.
Article VIII: Privacy of Minors
TxnGo Services are only available to users aged 18 and above. We do not knowingly collect information from individuals under the age of 18.
Article IX: Policy Amendments and Information Updates
Section 9.1 Policy Amendments
We have the right to amend this Privacy Policy. Upon amendment, the effective date at the top of this Policy will be updated. Material amendments will be notified to users through website announcements or other notices.
Section 9.2 Information Updates by Users
Users shall ensure that their personal data is accurate and up-to-date. Users may modify their information through their account settings. If they are unable to do so, they may contact customer service for assistance.