SAURUS PRIVACY AND COOKIES POLICIES
23rd November, 2020
These policies are drafted in accordance to the European Directive 95/46/C on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and explain what data we collect from you, when using any Saurus.com services or any such services provided by any such other brands owned or licensed by Rewire Holding LTD, (hereinafter Saurus, we, our, us), our websites, our APPs, our physical and/or cloud infrastructure or any of our products or services (hereinafter Products or Services).
These policies are legally binding, it sets out the basis on which any personal or business data we collect from you or your end-users using our Products or Services, or that you or your end-users provide to us. Please read the following carefully to understand our views and practices regarding your personal and/or business data and how we aim to treat it. When referring to you, as in anyone browsing our sites, or using our Products or Services or APPs we refer to you also as You, your, yours, your end-users, company, customer, user.
By using our Services and Products, you are accepting and consenting to the practices described in these Policies. If you do not agree to any part of these Policies, please do not use any of our Services nor Products and move away from any and all of our Services and Products.
- About us
For the purpose of the relevant data protection regulations, PFS (Prepaid Financial Services LTD) is the data controller of certain of your information in as far as the services provided by PFS to us and for those non-PFS services then Rewire Holding LTD or its subsidiaries is the data controller of your information as far as any such other services we provide to you and that are not contractually provided to us by PFS. We are registered in the UK, with company number 12344479. If after reading these Privacy and Cookies Policies you still have questions about anything in it, please stop using our Services and Products until you fully understand and accept all our Terms & Conditions and all our Privacy Policies and contact us at email@example.com .
- Information we collect
2.1 Information we collect from you
This information we collect from you is information that you give us by filling in forms on our website www.saurus.com or any such other websites that may be owned by us, our parent company or our subsidiaries (our sites), when you use our Products or Services from our site or our APPs, or by corresponding with us through our site, APP, by phone, e-mail, through social media or otherwise. It includes information you provide when you register, to use our site or our APP, subscribe to our Services, search for a Product, use any of our services in our site or our APPs, participate in discussion boards or other social media functions on our site or our social media channels, enter a referral program, competition, promotion or survey and when you report a problem with our site, our Products, Services or APPs.
The information you give us may include, but is not limited to, your full name, mailing and/or residence address, phone numbers, e-mail addresses, date of birth, nationality, country of fiscal residence, any of your identity documents and proof of address that we deem relevant, country of registration of business, any such information we deem relevant about your company and its shareholders and ultimate beneficiaries, your source of funds bank account details and account holder full name, any such financial and credit or debit card information we deem relevant, personal description and/or photograph of you (and if applicable all ultimate beneficiaries) and any such KYC & AML & ATF (know your customer & anti money laundering & anti terrorists financing) information and when applicable only also any such KYB (know your business) information as well as any compliance documentation we deem relevant.
We may also collect other information such as a copy of your government-issued identification and in certain cases a selfie image or a short video for verification purposes. Please ensure that you only send us an image, or video as applicable, of yourself or from your identification documents. Do not include any documents or images of others in the same selfie or video if applicable. When you contact our customer support or communicate with us in any other way, we’ll collect whatever information you volunteer to provide to us or you allow us access to, in addition to your name and email address.
2.2 Information we collect about you
With regard to each of your visits to our Site or App, or when you use our Services or APPs, we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer or mobile device to the Internet, your login information, browser type and version, device type and version, time zone setting, any such other identifiers, language, browser plug-in types and versions and operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products or things you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service.
- Name & Middle name and Surname(s)
Enter the full name you want to use on Saurus.com (“Saurus”). When you receive an email or interact with us or other user(s) of our Services or 3rd party financial providers, your name or any such other of your information will show up with it. Also, for information exchange in relation to KYC, KYB, AML, ATF or any such other contractual or legal compliance your name and any such other information about you might be exchanged.
- Personal information
Enter your birthdate, full address where you live (residence address), country of nationality, country of fiscal residence, photograph of yourself, a photograph of a valid identification document (passport, full UK driver license, EU country national ID card, EU country residence permit). This information is aimed to be used for internal and 3rd party KYC and compliance process to accept or decline a personal account opening request. It is your responsibility to keep this information up to date in the event of any relevant change, such as but not limited when you change your legal name, when you move to live in other address or country, or update your ID document when it expires
- Company Name
Only applicable if you open a company account with us. Enter the full name the company you represent to use on Saurus.com (“Saurus”). When you receive an email or interact with us or other user(s) of our Services or 3rd party financial providers, your company name and/or your personal name as a representative or any such other information of you will show up with it. Also, for information exchange in relation to KYC, KYB, AML, ATF or any such other contractual or legal compliance your name and any such other information about you might be exchanged.
- Company information
Only applicable in the event of a company account opening.
Enter the company representative personal information: your birthdate, full address where you live (residence address), country of nationality, country of fiscal residence, photograph of yourself, a photograph of a valid identification document (passport, full UK driver license, EU country national ID card, EU country residence permit). This information is aimed to be used for internal and 3rd party KYC and compliance process to accept or decline an account opening request. It is your responsibility to keep this information up to date in the event of any relevant change, such as but not limited when you change your legal name, when you move to live in other address or country, or update your ID document when it expires.
Enter the company information: company name, company number, registered company address, country of company registration, VAT number, certificate of incorporation, proof of legal representative document signed by a company Director or Executive to open and manage a company current account and cards, memorandum/articles of association, list of shareholders and ultimate beneficial owners of any shareholdings equal or more than 9%, company websites, description of the nature of the business and the source of current & future income/revenue. This information is aimed to be used for internal and 3rd party KYC / KYB and compliance process to accept or decline a business account opening request. It is your responsibility to keep this information up to date in the event of any relevant change, such as but not limited when you change your personal or company legal name, when your or your represented company address or country of registration changes, or update your representative ID document or any such company document when it expires or when it needs updating.
To help keep your account safe, choose a strong password that’s at least 10 characters, of which at least:
– 1 character must be an upper-case alphabet letter (A to Z)
– 1 character must be a lower-case alphabet letter (a to z)
– 1 character must be a number (o to 9)
– 1 character must be a special character of this list $@!%*-_=?&#
Have a mix of letters, capital letters, lower- and upper-case letters and numbers.
Avoid personal info or common words that are easy to guess, like your street or pet’s name.
Don’t use a password you’ve used for other accounts or websites. Likewise, don’t use this password anywhere else.
- Username – email address
Enter an email address that you’ll use to sign in to your Saurus Account, like in example firstname.lastname@example.org. This email address can be used for a few reasons, including to:
Help you get back in if you can’t sign in, like if you forget your password.
Get notifications from any of our Services.
- Change this info later
After you create a Saurus Account, you can change or update some of this info.
To assure you can use certain Saurus Services we need to check you are not a resident outside of the EEA list of countries. Also, to comply with the new European guidelines we need to check if you are a European territory User or not, in which case the new European data protection law requires such users´ data from European users to be stored on server(s) within a country of the European Union.
Also, for us to comply with our current and future contractual obligations and to comply with applicable laws, rules and regulations at any given time, such as KYC, KYB, AML, ATF and applicable TAX legislations and so forth we need to check the country of residence and the country of fiscal residency. When you create a Saurus Account, you provide us with personal information that includes your name, country and a password and other information. Even if you haven’t got an account with us yet and are applying for one or if you aren’t signed in to a Saurus Account, you might choose to provide us with information — like an email address or your country from where you access our sites or APPs to receive the information you are accessing, such as a website page or information about our service or APPs or when downloading our APP or when receiving updates about our Services or our sites or APPs.
- Your apps & devices
We collect information about the APPs, browsers, and devices you use on your device to access our Services, which helps us provide features like automatic product updates and dimming your screen if your battery runs low or to show you the information we deem relevant or in a certain language the information or service you access depending on your device’s information.
The information we collect includes unique identifiers, device/model type and settings, SIM mobile carrier name, SIM home country carrier, SIM, SIM telephone number if accessible, your device contacts list/phone book information if specifically authorised by you, your social network contacts list if your login is linked by you to one of those services, time zone, screen resolution and size if available, operating system, and installed applications APP names and version number and device file names and types. We also collect information about the interaction of your apps and devices with our services, including IP address, MAC address, crash reports, system activity, and the date, time, and referrer URL of your request.
We collect this information when a Saurus service on your device contacts our servers or our apps — for example, when you install our APP from the Play Store or App Store.
- Your location information
We collect information about your location when you use our services, which helps us offer features like nearby devices features that we may offer now or in the future, such as but not limited to Wi-Fi hotspots locations and hotspots names, Bumping payments between nearby Saurus Android smartphone users or between a Saurus user and a merchant compatible Saurus point of sale (POS) and it helps us to comply with the European regulations by checking if you are a European territory User or not, in which case the European data protection law requires us to store such European users´ data to be stored on server(s) within a country of the European Union.
Your location can be determined with varying degrees of accuracy by:
- Country of SIM, connected Mobile service provider (home or roaming). Name & country of your internet service provider (be it a fixed line or a wireless/mobile service provider), your SIM provider name and country code or roaming provider name and country code of the SIM in your device.
- IP address and MAC address
- GPS location information, such as but not limited to the country.
- Sensors data from your device, i.e. pressure data to calculate estimated altitude.
- Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices.
- The types of location data we collect depends in part on your device and account settings but mainly on the permissions access you provide us on your device. Certain feature of our Services may not function without certain such permissions. For example, you can turn your Android device’s location on or off using the device’s settings which is independent of our App(s).
- Your privacy controls
You have choices regarding the information we collect and how it’s used. You can revoke certain permission you make have provided through our Saurus APP by changing the settings of certain permissions in the settings menu of your device. Other permissions are mandatory to make use of our Services and can´t be revoked after you accept our Terms and Conditions (T&Cs) and Privacy Policies prior to creating an account with us or when browsing our sites. If you do not agree with any part of whole of any of our T&Cs or additional T&Cs or our Privacy & Cookies Policies or any of these or any other additional T&Cs and additional Privacy Policies or any such information we access, then simply stop using our services, uninstall all our APPs and browse away from all our sites.
When you visit our Site, app or use our Services or Products, we collect information about which of the Services you’ve used, from where you´ve used them and how you’ve used them. Examples, but not limited to, of this information include:
- Usage information on our Site or mobile app (e.g., pages you visit on the Site, webpage from which you linked prior to ending up on our Site).
- Time and date of your activities and location from which you browsed our Site or app.
- Information about your transactions, including the date, time, amount, beneficiary details, IP address, MAC address and other details of the transaction.
- Information about your transaction’s destination/source device and such account of each device of a same transaction identifier, including the date, time, amount, beneficiary/sender details, IP address, MAC address, location, country and other details of all device(s) that are part of a same transaction performed between nearby user´s devices of our Services.
- Device ID, IP address, MAC address and the kind of browser or app and the type of computer or mobile device you use.
- Name of your internet service provider or SIM provider or country code or roaming country code of the mobile operator SIM in your device; and Operating system version.
2.3 Information we get from 3rd parties
These 3rd party information that we receive about you if you use any of the other websites we operate or the other services we provide or if you browse 3rd party sites or use 3rd arty APPs that might link to our sites or APPs, for example but not limited to provide to their users certain or all of our services or who provide marketing or advertising services to us.
In this case we or the 3rd party might have informed you when we collected that data if we intend to share those data internally and combine it with data collected on our site. We aim to tell you for what purpose we will share and combine your data in future. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, financial services providers, etc.). We aim to notify you when we receive information about you from them and the purposes for which we intend to use that information.
We may collect Personal Information about you from other users, our affiliates, and third parties, as permitted by law or as authorized to be accessed by such other users. For example, we may collect information from third-party verification services, credit bureaus, financial institutions, mailing list providers, other users of our Services, and publicly available sources to verify your identity or fiscal residence or to obtain certain other information about you such as but not limited your email, contact phones and address etc. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law or as we deem fit to comply with our contractual obligations with 3rd parties and to ensure we have sufficient information about you for us to perform reasonable checks for KYC, KYB, AML, ATF, etc.
We may collect Personal Information about you from other users, our affiliates, and third parties, as permitted by law. For example, we may collect information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly or otherwise available sources to verify your identity or fiscal residence. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, compliance process, or collection procedure, or as may otherwise be required by applicable law.
How we use your information
3.1 To provide our services
Saurus may use your Personal Information to fulfil requests for Products, Services, or information, including information about potential or future Services, including but not limited to:
- Manage individual information and accounts, respond to questions, comments, and other requests;
- Verify an individual’s identity as being authentic or not and/or comparing your selfie image or video against your government-issued identification;
- Process payment for products or Services purchased, applications and transactions;
- Provide access to certain areas, functionalities, and features of our services and allow you to register for events or certain features of our Services.
3.2 For internal business purposes
Saurus may use your Personal or Business Information for its internal business purposes, including but not limited to:
- Measure interest in Saurus Services, develop new Products and Services or improve existing Products and Services.
- Ensure internal quality control and communicate about individual accounts and activities on Saurus Services and systems.
- Comply with regulatory requirements and prevent potentially prohibited or illegal activities.
- Protect the safety of any account, to address fraud, security or technical issues, or to protect the Company’s rights or property.
- Any of your personal or business information required to operate and provide to our users our Services and Products will be shared and stored on 3rdparty Suppliers servers or 3rd party Service Providers or any such other 3rd parties as required to provide any or all of our Services.
3.3 For marketing purposes
Saurus may analyse and use your Personal or Business Information to provide you with materials about offers, Products, and Services that may be of interest, including new content or Services, such uses include but are not limited to:
- To tailor content, advertisements, and offers.
- To notify you about offers, products, and services that may be of interest to you or to provide Services to you and our sponsors.
- For other purposes disclosed at the time you provide Personal Information; and otherwise with your consent.
- By using any of our Services or Products you consent to our Privacy and Cookies Policies.
- Legal Basis for using user’s information
According to data protection regulation we must have a legal basis to use your personal information, and will be one of the following:
When you agree to provide us information and allow us to collect it.
- It is necessary for the performance of a contract by us
When such information is necessary to perform a contract between Saurus and the user or between Saurus and a 3rd party contract to which Saurus is a party to.
- Compliance with a legal obligation
When Saurus as a controller or as a party to a contract with a 3rd party (in example PFS where PFS is the controller) has a legal or contractual obligation to perform the processing according to regulation or by contract.
- Legitimate interest
When processing any of your information is necessary for the purpose of legitimate interest of the controller or a 3rdparty, except when such interest is overridden by fundamental rights and freedom of the users which require protection of personal data.
- Sharing your data
We may share your personal data with 3rd parties in order to provide you with our services in the following ways:
- Business partners.
We may share Personal Information with our business partners, subsidiaries, parent company, affiliates, and for our affiliates’ internal business purposes or to provide you with a product or service that you have requested
5.2 To verify your identity.
For example, we may share information about you, but not limited to: with credit reporting agencies to verify your Social Security number or with 3rd party to verify authenticity of your identification document.
5.3 With vendors and service providers
(i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; and (iv) customer service activities; (v) fraud prevention; (vi) analytics services; and (vii) in connection with the provision of the Services. These service providers have contracted with us to only use the Personal Information for the purpose(s) for which the data were originally collected or may otherwise be lawfully processed.
5.4 With third parties for legal reasons
We may share information about you if we reasonably believe that disclosing the information is needed to:
- Comply with any valid legal or contractual process, governmental request, or applicable law, rule, or regulation.
- Investigate, remedy, or enforce potential Terms of Service or Privacy suspected violations.
- Protect the rights, property, and safety of us, our users, or others or Detect and/or report any fraud or security concerns.
- To comply with KYC, KYB AML and ATF.
- Cookies and analytics technologies
During the use of our website or app we mainly use three kind of cookies:
- Session cookies, they help websites recognise users and the information provided when they navigate through. Only retain information for as long as they are on website.
- Permanent cookies, they are capable of providing websites with user preferences, setting and information for future visits, improving their experience. They remain in operation even after the browser has closed. The law states that permanent cookies must be deleted after 12 months.
- Third party cookies, they are installed by third parties with the aim of collecting certain information from web users as the behaviour or spending habits. They are commonly used by advertisers who want to ensure that products and services are marketed towards the right target audience.
On most web browsers, you could find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.
We may also use analytics tools such as but not limited to Google Analytics to collect information regarding visitor behaviour and visitor demographics on our Site, and to develop website content and for marketing purposes. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.
6.2 Clear Gifs (web beacons)
We may employ a software technology called clear gifs (a.k.a. Web Beacons) that help us better manage content on our Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may tie the information gathered by clear gifs to our customers’ Personal Information. We may use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
- Sharing your data outside of the EEA
In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties outside of the European Economic Area. In these cases, we aim to ensure we take adequate and appropriate technical, physical and organisational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.
- Profiling and automated decision making
It is probable that we use some instances of your data to customise our Services and the information we provide to you, and to address your needs. For which we take all necessary measures to ensure that your privacy and security are protected, and we only use pseudonymised data where ever possible.
As we are a highly technical and innovative company, we may use Automated Decision Making (ADM) in order to improve your experience, or to help fight financial crime.
- Where we store your information
All information you provide to us is stored on a secure server or servers. Any transactions, specifically any payment transactions are aimed to be stored encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, app or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure.
Although we aim to do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or app; any transmission is at your own risk. Once we have received your information, we aim to use strict procedures and security features to try to prevent unauthorized access. Any information from European residents are aimed to be stored on servers in a country of the European Union.
- How long we keep your information
We will retain your information for as long as you use our Services or as necessary thereafter to fulfil the purpose(s) for which it was collected. However, as a Distributor of PFS (PFS being an institution regulated by the FCA), Saurus is required by contract and PFS by law to store some of your personal and transaction data even after the user closes the account. We do not control the use of your data by any 3rd party, however we will delete data under our control that is no longer required by any contract to which we are or will be a party to or by any relevant law or jurisdiction where we operate at any time.
- Your Rights
You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.
- You have the right to correct any personal information we have about you that is not accurate or not updated.
- You have the right to ask us to delete your personal information.
- You have the right to ask us to provide you with your personal information we held about you.
- You have the right to withdraw your consent given to us to process your personal data.
- You have the right to tell us about how we use your personal information.
You can exercise those rights at any time by contacting us at email@example.com
We take commercially-reasonable measures to protect the data you have given us from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. However, please be aware that no transmission of Personal Information over the Internet or the electronic storage of this information can be absolutely guaranteed to be free from unauthorized use or access. Before submitting any Personal Information via any of our Site, Services or our APPs, please keep in mind these risks and know that you do provide any of your personal or business information to us and indirectly automatically to certain 3rd parties (i.e. to PFS and others) at your own risk.
- Changes to our privacy policies
Saurus may change these Privacy and Cookies Policies from time to time. If we do, we will post the revised Policies on this page with a new date of when it was last updated by us. All changes will become effective when posted unless indicated otherwise. If we make any material changes we may choose, at our sole discretion, to post a notice on this website or to potentially send a notification to your Saurus app or to your email prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
- Exclusion of right of use
If you are not a resident of an EEA country or the UK, please move away from any and all of our services, and stop using all of our websites or APPs, as they exclude any non-EEA residents. You must be living / residing in Europe (includes any EEA country and also the UK) to use our service.
If you are not a resident of Europe (EEA and UK) and you ignore our explicit warning herewith that you have no right of use of any of our Services but still you use our Services or browse any of our websites or download any of our APPs than these and any such other terms and conditions and privacy policies apply for the rights of Saurus but none of the users rights apply to you at all, meaning you have no rights and any of your personal/business and other information will be extracted as described herein automatically and or as provided by you. If you do not agree with any of our Terms & Conditions or Privacy Policies then simply move away from our Site(s) and App(s) and do not use any of our Product(s) and Service(s). If you have used it by mistake or if a minor (under 18 years for EEA countries or under 16 years for UK) of your family used any of our website(s), APP(s), product(s) or any of our Service(s) by mistake or receives consequently any communications from us by APP notification, by email or any such other means, than please contact us and request to delete from our database all such minor user information and/or your own user info and corresponding account if any, by emailing such request to us.
If we detect now or in the future that any user who created an account with us, providing inaccurate or false or outdated information, then we will proceed to block such account to render our services not accessible (including our login feature) by that account user and notify you after that to the email you provided when you created the account and consequently a reasonable time after that notification we´ll close such user account permanently.
- Disclosure of information
By using any of our Service, websites or apps you agree irrevocably that we have the right to share your personal information with:
Any member of our staff or related entity within our group, parent or holding company or subsidiaries. – selected third parties including: – businesses, financial service providers, banks, credit or debit card providers, suppliers and sub-contractors, service providers, for the performance of any contract we enter into with you or with third parties or for providing our services through our apps, products, and our infrastructure, such as including but not limited by:
- analytics and search engine providers that assist us in the improvement and optimization of our sites or apps;
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. We will disclose your personal information to third parties:
- KYC/AML/Compliance agencies or third party contracted companies for such purpose of assessing your identity, living or fiscal address, anti-money laundry checks and checks for source of funds of money and crypto or other such services where this is a condition of us entering into a contract with you or such third party. We will disclose your personal information to third parties.
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Saurus sells part or all of its assets, or is acquired by a third party, in which case all your personal and if applicable your business data held by us about our customers (you) will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Saurus, or Saurus owners, or any of its officers, shareholders, customers, or others. This includes exchanging information with other companies and organizations for the purposes of financial compliance, customers fiscal address compliance verifications to comply with applicable laws, fraud protection and credit risk reduction and so forth.
Using any of our Service(s), website(s) or App(s) means you accept these Privacy and Cookies Policies but also that you accept irrevocably all our Terms of Service (Terms and Conditions or T&Cs) and any Additional Terms and Conditions, so read them carefully.
- Contact us
If you have questions or comments about these Privacy and Cookies Policies, please contact us at firstname.lastname@example.org .