Privacy Policy

1. Our Privacy Policy

1.1. At Oval Money, we are committed to respect and protect your privacy. This Privacy Policy sets out the type of information we collect from you and what we do with that information. The terms set out should be read together with our Terms and Conditions.

1.2. By using the service offered by Oval Money you confirm that you accept the terms of this Privacy Policy and that you agree to be bound by them in your use of the service. If you do not agree, please do not use the service.

2. Data Controller (or Owner)

2.1. For the purposes of this Privacy Policy, the Data Controller is Oval Money LTD (“Oval”, the “App” or “us”) of Flat G 88 Philbeach Gardens, Earls Court, London, England, SW5 9EU

2.2. We are also registered with the Information Commissioner under registration number: ZA219393.

2.3. You may contact us at: privacy@ovalmoney.com

3. 1. Data Processor

3.1.Amazon Web Services (AWS). AWS is appointed Data Processor by Oval. AWS provides the processing service of the Data collected through the use of the App. The processing of Data is carried out in respect of AWS Security Standards at all times. The information collected by AWS may be transferred to, or stored at, a location outside the European Economic Area (‘EEA’). To this end, AWS has enacted Model Clauses that allow the transfer of Data outside the EEA in compliance with European Data Protection law (Directive 95/46/CE) and with the General Data Protection Regulation (Reg. 679/2016).

3.2. Additionally, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies). The updated list of these parties may be requested from the Data Controller at any time.

4. Personal Data you give us

4.1. Oval collects, by itself or through third parties, Personal Data that includes: Full Name; Email; Mobile Phone number; Date of Birth; Country of Residence and Address; Nationality; Bank Account; copies of Personal Identification Documents (such as your Passport, ID, Driver License). The primary purposes in collecting information are to provide and improve our Service, to administer your use of the Service and to enable you to enjoy it.

4.2 Other types of Personal Data collected may be described in other sections of this Privacy Policy.

4.3 Failure to provide Personal Data may make it impossible for the App to provide its Service.

5. Information we collect from other sources

5.1. When you use our App we may receive or collect your IP address, URL, Browser information, operating system and platform as well as your login information. We may collect and store information about your location by converting your IP address into a rough geolocation or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. This information may be used to improve and personalize our service.

6. Bank Account and Financial Details.

6.1. The Service requires the processing in read only mode of your bank account details and financial data such as the history of your transaction and balance. To ensure the maximum level of protection of your Data, Oval collaborates with the following service providers that store and process User’s Data:

6.2. Salt Edge Inc. is an account aggregation service that allows the User to store its credit card and bank accounts’ credentials. Oval has sign up for the Bank Integration Program offered by Salt Edge Inc. and to use the App you shall link your bank account(s) to the App by using Salt Edge’s platform service. Salt Edge will allow you to connect with your bank account(s) using your online login credentials and will store them s through a bank-level security system. Oval will never receive nor store User’s personal online login credentials and will receive from Salt Edge only the information required to provide the service.

  • Collected Data: Full name, Email, Mobile Phone Number, Date of Birth, Nationality, Country of Residence and Address, Bank Account and other Financial Details, as specified in Salt Edge’s Privacy Policy..
  • Place of processing: Canada – Privacy Policy

6.3.Mangopay. Mangopay is the Application Programming Interface (‘API’) provided by Mangopay SA to issue and manage the distribution of e-money (as defined by Directive 2009/110/EC ‘E-Money Directive’) directly to the User. Through Mangopay’s service, Oval, as an e-money distributor, offers a payment solution for all transactions made by Users within the App. The payment solution is based on the e-money issued by Mangopay upon the demand and for the accounts of Users. The e-money is stored in a Mangopay’s electronic wallet (‘e-wallet’) specifically opened by the User. Mangopay is an autonomous Data Controller as to the service it provides and by opening a Mangopay account Users agree to be bound by Mangopay’s Terms and Conditions and Privacy Policy.

  • Collected Data: Full name, Email, Mobile Phone Number, Date of Birth, Nationality, Country of Residence and Address, Bank Account and other Financial Details as specified in Mangopay’s Privacy Policy.
  • Place of processing: Luxembourg – Privacy Policy
7. Other uses of the Data collected

The Data we collect from Users are also used for the following purposes:

  • Registrazion. Through User registration or authentication, you give Oval your consent to be identified and to access the App’s services.
    1. Facebook Authentication (Facebook, Inc.). Facebook Authentication is a registration and authentication service provided by Facebook, Inc., related to the social network Facebook.
    2. Collected Data: Public Profile, Email, Friends, Date of Birth, Events, Location, likes and pictures
    3. Place of processing: US – Privacy Policy
  • Instagram Authentication (Instagram Inc.).. o Instagram Authentication is a registration and authentication service provided by Instagram, Inc.
    1. Collected Data: Shared Data: Public Profile, Email, User’s Friends, Date of Birth, Events, Location, likes and pictures
    2. Place of processing: US – Privacy Policy
  • Analytics. The services described in this section allow the Data Controller to control and analyze traffic data. The services also allow the tracking of the User’s behavior.
    1. Fabric is an analytics service provided by Google, Inc. Data collected: different types of Personal Data, such as Usage Data, as specified in the Privacy Policy of Fabric.
    2. Place of processing: US – Privacy Policy
  • Email and Contact Management. These services allow the managing of email contacts and other contacts used to communicate with the User. The services may also allow the collection of Data concerning the date and time of display of the message by the User.
    1. Mailchimp, Mailchimp is an email management and storage service provided by Mailchimp Inc. Data collected: Email.
    2. Place of processing: US – Privacy Policy
    3. Intercom is a communication platform developed by Intercom Inc. focused on communication with the User. Data collected: Email and Name
    4. Place of processing: US – Privacy Policy
    5. Newsletter By registering to the newsletter service, the User’s email address is inserted in a mailing list. They will receive emails containing information, also of commercial and promotional nature, regarding Oval. Data collected: Email and Name.
  • Advertising
    1. This type of services allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
    2. AdWords. AdWords is a remarketing and behavioral targeting tool to advertise across websites provided by Google, Inc. Data collected: Usage Data and various types of Data, as specified in AdWords’ Privacy Policy.
    3. Place of Processing: US – Privacy Policy
    4. Facebook Conversion. Facebook Conversion is a tracking tool for ads on the social network Facebook provided by Facebook, Inc. Data collected: Usage Data and various types of Data as specified in Facebook’s Privacy Policy.
    5. Place of processing: US – Privacy Policy
8. Mode and Place of Processing the Data

8.1. Misure di sicurezza

8.1.1 Oval processes Users’ Personal Data in a proper manner and shall adopt appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. Even where all precautions are adopted we cannot guarantee complete security in all events.

8.1.2. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

8.2. Place of processing

8.2.1. The Data is processed at the Data Controller's operating offices and where the Data Processor’s operating offices or other parties involved with the processing are located.

8.3. Retention time

8.3.1. The Data is kept strictly for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this Privacy Policy.

8.3.2 The User may always request that the Data Controller suspend or remove the Data.

9. Data Transfer

9.1. The User consents to the transfer of the collected Data through the Service in the event of rearrangement, merger, sale, joint venture, transfer or any other arrangement method of the whole or part of the Company, of its goods and shares.

10. Legal Action

10.1. Your Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this App or related services.

10.2. You acknowledge to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

11 Rights of Users

11.1. You have the right, at any time, to know whether your Personal Data has been stored and may consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any Data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at: privacy@ovalmoney.com

12. Changes to the present Privacy Policy

12.1 The Data Controller reserves the right to change this Privacy Policy at any time by giving notice to its Users through this page. It is recommended, therefore, to check this page often and refer to the latest update date at the bottom of the page. If a User objects to all or any of the changes to the Policy, you must cease using the App and may request that the Data Controller remove yourr Personal Data. Unless stated otherwise, the then-current Privacy Policy applies to all your Personal Data processed by the Data Controller at the time.

Definitions

Personal Data (or Data)

Any information regarding a natural person, which is, or may be, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this App (or Third Party services employed in this App), which may include: IP addresses or domain names of the computers used by the Users, URI addresses (Uniform Resource Identifier), time of the request, method of request submission to the server, size of the file received in response, numerical code indicating the status of the server's answer (successful outcome, error, etc.), Country of origin, features of the browser and the operating system utilized by the User, various time details per visit (e.g., time spent on each page within the App) and details about the process followed within the App, specifically the visited pages sequence and other parameters about the device operating system and/or the User's IT environment..

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization, also jointly with another Data Controller, having the right to make decisions regarding the purposes and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this App. The Data Controller, unless otherwise specified, is the Owner of this App.

User

The individual using this App, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refer.

Data Processor

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Last updated: 09/09/2017