Effective Date: 1 August 2016.
This website, www.goldmoney.com (the “Website”) is owned and operated by Goldmoney Inc.
This policy sets out:
- what information we collect and why we collect it;
- how we use that information; and
- the choices you have with regard to the use of your personal information.
A. WHAT WE COLLECT
1. Depending on the type of Goldmoney Services you use, the information we collect about you may include:
- contact information (such as your name, email and postal addresses, telephone number, and country of residence) that you provide by completing forms on the Website, by telephone, or through a paper application form;
- information permitting us to offer the Goldmoney Services to you, including details relating to your personal bank accounts or virtual currency wallet, details allowing us to prevent and detect money laundering and terrorist financing activities, copies of your current valid government-issued photo identification, and/or such other identifying and verifying information as we require from time to time in our discretion, and credit bureau information about you for purposes of confirming your identity under applicable "know-your-client" rules;
- details about your finances that you provide to us or permit us to collect through third party service providers;
- your login and password details;
- details of any transactions you make through the Goldmoney Services;
- information about your activity on the Website, such as your IP address, the pages you have visited and the device or browser you use;
- information provided via your mobile devices, such as your location, phone ID, mobile user name, password, contacts, location;
- communications with us (for example, when you ask for support, send us requests, questions or comments, or report a problem, whether by mail, telephone, fax, online, or by any other means);
- information that you submit through the Website, including in the form of comments, contributions to discussions, or messages to other users; and
- demographic information;
- geolocation information;
- data mining and financial profiling.
2. When you opt in for our Newsletter, or marketing materials, we collect your email address and name.
3. As is true of most websites, but subject to your browser settings, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages and operating system.
4. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
B. HOW WE USE YOUR PERSONAL INFORMATION
1. We need to use the personal information described in section A in order to offer the Goldmoney Services to you, including for the following purposes:
- Ascertaining whether to approve you for use of the Goldmoney Services when you apply to use the Goldmoney Services;
- Identifying you when you sign in to your Goldmoney Wealth Holding or Goldmoney Personal or Business Account;
- Processing transactions in your Goldmoney Wealth Holding or Goldmoney Personal or Business Account, helping you submit your Bitcoin transaction request for confirmation to the Verification Network, and communicating with recognized counterparties, bullion-dealers, bullion-banks, and vault operators in respect of the Goldmoney Services;
- Administering your Goldmoney Wealth Holding or Goldmoney Personal or Business Account, understanding your needs as a client, and monitoring your satisfaction with the Goldmoney Services;
- Contacting you about the status of the Goldmoney Services (for example, to inform you of changes to or the termination of particular Goldmoney Services, or to respond to a question, comment or complaint);
- Complying with legal requirements, including those imposed by laws, regulations, court orders, and regulatory guidelines, policies and procedures, in the countries in which we operate, including tax, "know your client" and Anti-Money Laundering obligations, requirements applicable to Goldmoney Inc as a Dealer in Precious Metals and Goldmoney Wealth Limited as a regulated Money Services Business, international electronic funds transfer obligations, or reporting obligations;
- Detection of suspicious transactions, including transactions involving fraud, money laundering or terrorist financing activities;
- Managing invoicing, accounting and information security services related to our transactions with you;
- Protecting against harm to the rights, property or safety of Goldmoney, its clients, employees, service providers, or the public;
- Internal management purposes, including planning, resource allocation, policy development, quality improvement, compliance, monitoring, audit, evaluation and reporting;
- Improving the Goldmoney Services;
- Managing your communications preferences; and
- Maintaining ownership records.
2. When you contact Goldmoney, we may keep a record of your communication to assist us and you in ensuring that you get the best from our services.
C. HOW WE SHARE YOUR PERSONAL INFORMATION
1. From time to time, we engage unaffiliated third parties and their affiliates, agents, and subcontractors ("Service Providers") to perform certain technological or administrative services in connection with the Goldmoney Services. For example, a Service Provider may be asked to serve as a Vault Operator, operate a Verification Network, process transactions, provide credit reports or assessments, verify customer identities, detect suspicious transactions, perform security services, and manage or audit our operations. In some cases, a Service Provider will be collecting your personal information from other sources on our behalf to fulfil the purposes set out in section B. We also may use a Service Provider to host and administer one or more of our Websites, process and store data, and fulfil similar technology-related functions on our behalf. In these circumstances, the personal information that the Service Provider receives is limited to the personal information needed to render their service to us.
2. In certain cases, we may also share some of the personal information we collect with carefully selected business partners, who are first required to sign an agreement that obligates them to keep the information confidential and secure and prohibits them from using it for unauthorized purposes.
3. We may disclose personal information without notice to you if a law, regulation, search warrant, subpoena, court order, or regulatory notice permits or requires us to do so. We may also disclose personal information without notice to you to prevent fraud or abuse, or to protect the rights, property or personal safety of Goldmoney, its customers, employees, service providers, or the public.
4.For clients of Goldmoney Personal and/or Business, the data controller is based in Toronto, Canada. For clients of Goldmoney Wealth, the data controller is based in Jersey, Channel Islands, and data is stored in Jersey, Channel Islands and in other locations within the EEA. Goldmoney reserves the right to share your personal information internally between Toronto, Canada, and the EEA to the extent necessary for the purpose of providing Goldmoney Services to you. By signing up for Goldmoney Services, you agree to the data controllers sharing information with each other. Should you not consent to such disclosures between , please do not utilise Goldmoney Services.
5.Goldmoney will treat as confidential all information it holds in relation to a client where that information is not in the public domain. Subject to this clause, Goldmoney will not disclose such confidential information to third parties.
7.We may provide your personal information to companies that provide services to help us with our business activities such as emailing newsletters or offering client service. These companies are authorized to use your personal information only as necessary to provide these services to us.
8.We may share aggregated, non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends or publish market research.
9.We will disclose otherwise confidential personal data and confidential information if we are compelled to do so by laws and regulations applicable to us and/or our agents, and whether in Jersey or elsewhere.
D. HOW WE COMMUNICATE WITH YOU
1.Communications between you and Goldmoney may be conducted by mail or by telephone, fax, online, text message, or by other electronic means. Any instructions that you give to us in any such manner will have the same legal effect as if you gave them to us in original written form. You agree that all telephone calls and electronic communications may be recorded and kept by us as a record of your instructions. You also agree that we may contact you electronically in response to a request, inquiry, or complaint, as otherwise solicited by you, or as permitted or required by law.
E. INFORMATION STORAGE AND RETENTION
2.Your information may also be processed by employees or consultants of the Group who are located outside of the EEA. By submitting your personal data, you agree to this processing, storing, and transfer.
F. COOKIES AND OTHER TRACKING TECHNOLOGIES
1.As is true of most websites, but subject to your browser settings, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
2.We use this information, which does not identify individual users, to analyse trends, to administer the site, to track users' movements around the site, and to gather demographic information about our user base as a whole.
3.We do not link this automatically collected data to personally identifiable information.
- It is always open to you to modify your web browser settings to prevent the placing of cookies or to notify you each time a cookie is set. The website www.allaboutcookies.org contains additional useful information on how to block or control cookies using different browsers. However, by blocking or deleting cookies used on the Goldmoney Services, you may not be able to take full advantage of the Goldmoney Services.
6.Goldmoney uses, through its Website, the Google Adwords and Adroll Remarketing services to advertise on third party websites (including Google) to previous visitors to the Website. Google AdWords Remarketing is a remarketing and behavioural targeting service provided by Google. It connects activity on www.goldmoney.com with the Adwords advertising network.
7.Google AdWords Remarketing displays relevant advertisements to you based on pages of the Goldmoney Website that you have viewed by placing a cookie on your computer. This cookie does not identify you or give us access to your computer. The cookie allows us to show you relevant advertisements across the Google Advertising Network based on your previous browsing of the Goldmoney website.
You can opt out of Google Adwords Remarketing by visiting: http://www.google.com/settings/ads
You can opt out of all third party cookie advertising by visiting: http://www.networkadvertising.org/choices
G. CHANGES TO THIS POLICY
Last updated: 1 August 2016