Privacy Policy (ENG)

In this Privacy Policy, Global Ukraine Banking App (hereinafter: “Global Ukraine”, “we”, “our”) shall inform you about the collection, use and processing of personal data when using our website https://global-ukraine.com/ (hereinafter: “Website”) and our mobile app (hereinafter: “App”; jointly called: “Services”). We will explicitly point out in case any information of this Privacy Policy refers exclusively to our Website or App. For information related to the usage of cookies or similar technologies on our Website or Apps, please refer to the respective website and app cookie policies in the legal documents section of your app or on our websites.

In this context, personal data means all detailed information about personal or factual circumstances of a specific or identifiable natural person, such as name, telephone number or address. We process your personal data either within our business relation if you are a Global Banking App customer or when you are visiting our Website for informative purposes. Furthermore, we process personal data coming from publicly accessible sources (e.g. records of debtors, trade registers, registers of associations, media, press, internet) whenever we have a legal ground that allows us to do so.

When using additional Global Ukraine Banking App products or products of our business partners, additional personal data might be collected, processed and stored. Please find details concerning the processing of additional data in the respective product category below.

We’re 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;

What personal data we collect?

We collect information you provide when you:

  • fill in any forms
  • correspond with us
  • respond to any of our surveys
  • register to use the Global Ukraine Banking App
  • open an account or use any of our services
  • give us access to your other financial accounts (for example, through Open Banking)
  • take part in online discussions or promotions
  • speak with a member of our social media or customer support teams (through Telegram or through the Global Ukraine Banking App)
  • enter a competition or share information with us on social media
  • contact us for other reasons

We will collect the following information:

  • your name, address, and date of birth
  • your email address, phone number and details of the device you use (for example, your phone, computer or tablet)
  • your Global Ukraine Banking App username (this is random and is automatically assigned to you when you first join but you will be able to change it)
  • your registration information
  • details of your bank account, including the account number and IBAN
  • details of your Global Ukraine Banking App debit cards and credit cards (or other debit or credit cards you have registered with us) including the card number, expiry date and CVC (the last three digits of the number on the back of the card)
  • copies of your identification documents (for example, your passport or driving licence) and any other information you provide to prove you are eligible to use our services
  • your country of residence, tax residency information, and tax identification number
  • information you provide when you apply for credit, including details about your, or your spouse’s, income and financial obligations
  • records of our discussions, if you contact us or we contact you (including records of phone calls)
  • your image in photo or video form (where required as part of our Know-Your-Customer (KYC) checks, to verify your identity if you contact us when logged out of your Global Ukraine Banking App account, or where you upload a photo to your Global Ukraine Banking App account).

Whenever you use our website or the Global Ukraine Banking App, we collect the following information:

  • technical information, including the type of device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system and the type of mobile browser you use
  • information about your visit, including the links you’ve clicked on, through and from our website or app (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page
  • information on transactions and your use of Global Ukraine Banking App products (for example, payments into and out of your account), including the date, time, amount, currencies, exchange rate, beneficiary details, details of the merchant or ATMs associated with the transaction (including merchants’ and ATMs’ locations), IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received, details of device used to arrange the payment and the payment method used
  • information stored on your device, including if you give us access to contact information from your contacts list. The Global Ukraine Banking App will regularly collect this information in order to stay up to date (but only if you have given us permission)

 

Global Ukraine Banking App can transmit your personal data to other entities such as other financial institutions, regulatory and supervisory authorities as well as public and governmental bodies and agencies, including addition to that the ECB (European Central Bank), the EBA (European Banking Authority) among other entities, who will act as separate data controllers of your personal data, for the purposes of:

  • Enforcement of claims and defense within legal disputes, based on the legitimate interest of Global Ukraine Banking App of exercising its right of defense before courts/competent authorities;
  • Complying with legal obligations regarding regulatory, tax and anti-money laundering reporting requirements;
  • Fraud prevention, based on the legitimate interest of Global Ukraine Banking App not to contract or provide services to any potential customer related to fraud;
  • Preventing criminal acts, based on the legitimate interest of Global Ukraine Banking App not to contract or provide services to any potential customer related to any crimes.

Global Ukraine Banking App can transmit your data to external lawyers, advisors and consultants, who are separate controllers and bound to professional confidentiality, for the purposes described above.

 


What we use your personal data for Our legal basis for using your personal data

Providing our services

Whenever you sign up with Global Ukraine Banking App, apply for or use a product or service, we’ll use your personal data to:

  • check your identity, and the identity of joint account holders (as part of our KYC process);
  • decide whether or not to approve your application;
  • meet our contractual and legal obligations relating to any products or services you use (for example, making payments into and out of your Global Ukraine Banking App account, withdrawing cash or making payments with your Global Ukraine Banking App card);
  • help you understand your spending behaviour, how you use Global Ukraine Banking App products and services, and to help you save money (for example, by providing you with product usage and spending insights)
  • recover debt and exercise other rights we have under any agreement with you
  • provide you with customer support services. We may record and monitor any communications between you and us, including phone calls, to maintain appropriate records, check your instructions, analyse, assess and improve our services, and for training and quality control purposes
  • Keeping to contracts and agreements between you and us;
  • Legitimate interests (we need to be efficient about how we meet our obligations and we want to provide you with good products and services);
  • Legal obligations.

Protecting against fraud

We use your personal data to check your identity to protect against fraud, keep to financial crime laws and to confirm that you’re eligible to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your Global Ukraine Banking App account.
  • Legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities);
  • Legal obligations.

Marketing and providing products and services that might interest you

We use your personal data to do the following:

  • to personalise your in-app experience and marketing messages about our products and services so they’re more relevant and interesting to you (where allowed by law). This may include analysing how you use our products, services and your transactions;
  • if you agree, provide you with information about our partners’ promotions or offers which we think you might be interested in;
  • if you agree, allow our partners and other organisations to provide you with information about their products or services;
  • measure or understand the effectiveness of our marketing and advertising, and provide relevant advertising to you;
  • ask your opinion about our products or services.
  • Legitimate interests (to send direct marketing, ensure our direct marketing is relevant to your interests, develop our products and services, and to be efficient about how we meet our legal and contractual duties);
  • Consent (where we’re legally required to get your consent to send you direct marketing about our products or services, or partners’ promotions or offers, or for you to receive marketing from other organisations).

To keep our services up and running

We use your personal data to manage our website and the Global Ukraine Banking App, (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content is presented in the most effective way for you and your device.

 

We also use your personal data to:

  • verify your identity if you contact our customer support or social media teams;
  • allow you to take part in interactive features of our services;
  • tell you about changes to our services.
  • help keep our website and the Global Ukraine Banking App safe and secure
  • Keeping to contracts and agreements between you and us;
  • Legitimate interests (to be efficient about how we meet our obligations and keep to regulations that apply to us and to present content as effectively as possible for you);
  • Consent (where required by law).

Helping with social interactions

We use your personal data to help with social interactions through our services, or to add extra functions in order to provide a better experience.

For example, if you give us permission, we'll use the contacts list on your phone so you can easily make payments to, or message, your contacts using the Global Ukraine Banking App.

 
  • Legitimate interests (to develop our products and services and to be efficient in meeting our obligations)
  • Consent (to access information held on your phone, for example, contacts in your contacts list, to track you when you have location services switched on)

Providing location-based services

If you turn location services on in the Global Ukraine Banking App, we use your personal data to:

  • provide you with products and services;
  • provide relevant advertising to you (for example, information about nearby merchants);
  • protect against fraud.
  • Keeping to contracts and agreements between you and us
  • Legitimate interests (to develop and market our products and keep to regulations that apply to us)
  • Consent (to track you when you have location services switched on)

Preparing anonymous statistical datasets

We prepare anonymous statistical datasets about our   customers’ spending patterns:

  • for forecasting purposes;
  • to understand how customers use Global Ukraine Banking App;
  • to comply with governmental requirements and requests.

These datasets may be shared internally or externally with others, including non-Global Ukraine Banking App companies. We produce these reports using information about you and other customers. The information used and shared in this way is never personal data and you will never be identifiable from it. Anonymous statistical data cannot be linked back to you as an individual.

 

For example, some countries have laws that require us to report spending statistics and how money enters or leaves each country. We’ll provide anonymised statistical information that explains the broad categories of merchants that Global Ukraine Banking App customers in that country spend their money with. We’ll also provide information about how Global Ukraine Banking App customers top up their accounts and transfer money. However, we won’t provide any customer-level information. It will not be possible to identify any individual Global Ukraine Banking App customer.
  • Legitimate interests (to conduct research and analysis, including to produce statistical research and reports)
  • Legal obligations

Improving our products and services

We use your personal data to help us develop and improve our current products and services. This allows us to continue to provide products and services that our customers want to use.
  • Legitimate interests (to understand how customers use our products so we can develop new products and improve the products we currently provide)

Meeting our legal obligations, enforcing our rights and other legal uses

We use your personal data:

  • to share it with other organisations (for example, government authorities, law enforcement authorities, tax authorities, fraud prevention agencies)
  • to recover debts from you (for example, where you hold a credit product with us or have a negative balance in your account)
  • if this is necessary to meet our legal or regulatory obligations;
  • to identify and support vulnerable customers by analysing your behaviour in the Global Ukraine Banking App, customer support communications and through transactions (for example, we will try to identify whether you are potentially vulnerable so we can provide you with enhanced support. Identifying and supporting vulnerable customers is a legal requirement for us in some countries);
  • in connection with legal claims;
  • to help detect or prevent crime.
  • Legitimate interests (for example, to protect Global Ukraine Banking App during a legal dispute)
  • Substantial public interest (if we process your sensitive personal data to keep to legal requirements that apply to us)
  • Legal obligations

To help protect the banking system and to assist you in filing your tax returns, we also share your tax information number and the description of your sub accounts with the Tax Authorities.

 

We process and store your data as long as you remain a Global Ukraine Banking App user. We only keep your data for the time necessary to fulfil the purpose of collection. You may request us to close your account at any time and delete your data after account closure. We may retain certain data after account closure due to legal or regulatory requirements. We are legally obliged to retain certain data for a minimum of 5 to 7 years after ending the customer relationship and in other cases up to 10 years, as in the case of accounting obligations.

 

We are able to store personal data for longer periods with a valid legal ground, or when the data is sufficiently pseudonymised or anonymised.

 

We recognise the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.

 

We use a variety of physical and technical measures to:

  • keep your personal data safe
  • prevent unauthorised access to your personal data
  • make sure your personal data is not improperly used or disclosed

 

Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means. Our staff receives data protection and information security training. We have detailed security and data protection policies which staff are required to follow when they handle your personal data.

 

In order to gather analytics to analyse the use of our products and services, we use Hubspot (Hubspot Ireland Limited, Ground Floor, Two Dockland Central, Guild Street, Dublin, D01R8H7). We have signed a data processing agreement with Hubspot in order to guarantee it to be privacy friendly, and we have disabled data sharing where possible. In addition, check out Hubspot’s cookie policy for more information on how their cookies work and how to opt-out for their cookies https://legal.hubspot.com/cookie-policy.

 

While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorised access, we cannot guarantee it will be secure during transmission by you to our app, a website or other services. We use HTTPS (HTTP Secure), where the communication protocol is encrypted through Transport Layer Security for secure communication over networks, for all our app, web and payment-processing services.

 

If you use a password for the Global Ukraine Banking App app you will need to keep this password confidential. Please do not share it with anyone.

 

You have the following rights concerning your personal data:

  • right to revoke your consent according to Art. 7 (3) GDPR, which is detailed in section XI.2. below
  • right of access according to Art. 15 GDPR, which means you can request information on whether your personal data is being processed by Global Ukraine Banking App and information on the particular processing of personal data, at any time, along with a copy of the information processed. In no case this right covers the access to documents or the obtention of copies of such documents;
  • right of rectification according to Art. 16 GDPR, which means you can request the rectification of your data when they are incomplete or inaccurate;
  • right to erasure according to Art. 17 GDPR, which means you can request the deletion of your personal data when they are no longer required by Global Ukraine Banking App for the purposes they were initially collected for, or when you understand they have been illicitly used. Global Ukraine Banking App can reject your request, if the data is necessary to comply with a legal obligation, for public interest reasons or for legal actions;
  • right to restriction of the processing according to Art. 18 GDPR, which means you can request the restriction of the processing of your personal data when it is legally permitted and, in particular, (i) while you challenge the accuracy of your data, (ii) when you request the restriction of your data because you believe the processing is unlawful, or (iii) when the data is no longer needed for the purposes for which it was collected but Global Ukraine Banking App needs them for legal actions;
  • right to object to the processing according to Art. 21 GDPR, which is detailed in section XI.2. below;
  • right to data portability according Art. 20 GDPR, which means you can request Global Ukraine Banking App to provide you personal data, in a structured, commonly used and machine-readable format and to transmit your data to another controller where the data processing is based on the consent, or on a contract and the processing is carried out by automated means;
  • Right to lodge a complaint with a supervisory authority according to Art. 77 GDPR, which means that you can complain before the supervisory authority if you consider that the processing of your personal data by Global Ukraine Banking App infringes the GDPR.

 

We are always improving and expanding our products and services. This might cause our data processing to change. When we change something, we will adjust our Privacy & Cookie Statement accordingly. You can always find the latest version on our website and in the app.

 

If you would like more information, please contact us by sending an email to office@global-business-hub.com .