Privacy Policy

What is Personal Data

Personal data is any information that relates to an identified or identifiable living individual (data subject). Different pieces of information, which collected together can lead to the identification of a particular person also constitute personal data.

This includes your first and last name, identification number, e-mail address, address, contact number, education and training records, employment data, financial and banking data, photographs and videos, as well as data related to cookies, online identifiers, and demographics.

Our role under the Regulation

Under the Regulation, MONEYRIVER is the Data Controller or might be joint Controller under specific agreements, for all the personal data it maintains and processes. Depending on our business relations, we may act as a Data Processor, processing personal data as per the means and purposes defined by the Data Controller.

We are committed to protecting and respecting your privacy. We will:

• Always keep your personal data safe and private
• Never sell your personal data
• Allow you to manage and review your marketing choices at any time

How we collect Personal Data

We may collect your Personal Data:

• Directly from you
• Through third parties in the standard course of business
• Through our Company website, when you contact us directly or via our Contact Us form
• Through our associates and collaborators

Types of Personal Data Collected

We collect and use several types of data for the individuals we co-operate with, including:

• Data that you provide by filling in forms, in particular at the time of first contact with us
• Data when you report a problem with our Website/service
• Records and copies of your correspondence (including e-mail addresses)
• Employment data when you have an employee relationship with us
• Data that you provided your Bank for the provision of specific services, upon your explicit consent

Purposes for Which We Use Your Personal Data

We might process your personal data for the following purposes:

• Provision of services: to provide you with the services for the provision of specific banking services we promote
• Customer management: to manage your account, provide customer support, and notify you about changes
• Functionality and security: to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement
• Compliance: to enforce our Terms and Conditions and comply with legal obligations
• Advertising: following explicit consent to communicate with you about products or services of interest
• Public functions: in the exercise of official authority or to perform a specific task in the public interest

Disclosure of Your Personal Data

We shall not share your Personal Data with third parties except:

• Affiliates: We share Personal Data with our affiliates to the extent necessary for provision of services, customer management, security and compliance
• Service providers: We use third party service providers for application development, hosting, payment processing, customer support and other services. Some third parties may be located outside of your location; we have taken all reasonable steps to ensure they comply with data protection regulations

We may also disclose your Personal Data to official authorities, courts, or other public bodies in response to legal requests, to establish or exercise our legal rights, to defend against legal claims, or to comply with applicable law.

How We Store Your Personal Data

To bring you our Services, we operate both within the European Economic Area (EEA) and also outside the EEA. When your personal information is transferred outside the EEA, it will only be transferred to countries that have been deemed to provide adequate protection for EEA information, or to a third party where we have approved transfer mechanisms in place to protect your personal information.

Retention of Personal Data

We generally retain your information only as long as reasonably necessary to provide you the Services or to comply with applicable law. However, if you request that we delete your data, we will also delete your data from our Services unless we are required to retain it according to applicable law. For further data regarding specific retention periods please contact us at gdpr@cobbypay.com

Legal Bases for Processing

We rely on the following legal bases:

• Performance of contract: Providing our Service, customer management and functionality as described in our Terms and Conditions
• Compliance with legal obligation: Processing required to comply with a legal obligation to which we are subject
• Protection of vital interests: Processing necessary to protect your vital interests when you are physically or legally incapable of giving consent
• Legitimate interests: Processing necessary for our legitimate interests or those of a third party, except where overridden by your interests or fundamental rights
• Consent: For marketing and advertising purposes, and other purposes for which we specifically ask your consent

Your Rights under GDPR

Subject to the provisions of the GDPR, you have the following rights:

• Right of Access: Access your own Personal Data and request a copy
• Right of Rectification: Request the correction of incomplete or inaccurate data
• Right to Erasure: Request deletion of personal data when no longer necessary
• Right to Object: Oppose the processing of your Personal Data for reasons related to a specific situation
• Right to Restriction of Processing: Request the restriction of processing of your Personal Data
• Right to Data Portability: Request the transfer of your personal data in a structured, machine-readable format
• Right to Object to Automated Decision-Making: Request that no decision is made solely on the basis of automated processing

To exercise any of your rights, please send a written request to gdpr@cobbypay.com

Automated Decision-Making

By using our services, you expressly consent to the automated decision-making and profiling practices described in this section. We may use algorithms, data analysis, and artificial intelligence to make decisions that impact your access to certain features, services, or benefits.

You have the right to obtain human intervention, express your viewpoint, and seek a review of any automated decision that significantly affects you.

How We Protect Your Personal Data

We take all appropriate security technical and organisational measures (including physical, electronic and procedural measures) to safeguard your Personal Data from unauthorized access, unlawful use, intervention, modification or disclosure under the requirements of the Regulation.

Changes to Our Privacy Policy

We may modify or revise our Privacy Policy from time to time. Although we may attempt to notify you when major changes are made, you are expected to periodically review the most up-to-date version found at cobbypay.com so you are aware of any changes, as they are binding on you.

Contact

If you have any questions about this privacy policy or our data-handling practices, please contact us at gdpr@cobbypay.com

If you feel that your concerns have not been addressed, you have the right to submit a complaint with the Personal Data Protection Commissioner’s Office at dataprotection.gov.cy