Privacy Policy

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1. ABOUT US

2. WHAT INFORMATION DO WE COLLECT FROM YOU?

3. HOW DO WE COLLECT YOUR DATA?

4. WHAT WE DO WITH YOUR DATA?

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. HOW LONG WE WILL KEEP YOUR DATA FOR?

9. YOUR LEGAL RIGHTS

1. ABOUT US

Purpose of this privacy policy

This privacy policy aims to give you information on how 3S Money (Luxembourg) S.A. collects and processes your personal data through your use of this website and our services, including any data you may provide through this website when you process payments, take actions relating to your account, communicate with our Client Managers and during the onboarding process.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware.

Controller

3S Money: 3S Money (Luxembourg) S.A.,  Luxembourg R.C.S. number B245715, authorised by the Commission de Surveillance du Secteur Financier (CSSF) under the law of 10 November 2009 on payment services for issuing, distribution and refund of electronic money with the CSSF registration number W00000016, is the controller and is responsible for the processing of your personal data (collectively referred to as "3SM", "we", "us" or "our" in this privacy policy).

We personally oversee all questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

You have the right to make a complaint at any time to the CNPD, the National Commission for Data Protection in Luxembourg (https://cnpd.public.lu/en/support/contact.html). We would, however, appreciate the chance to deal with your concerns before you approach the CNPD so please contact us in the first instance.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: 3S Money (Luxembourg) S.A.

Email address: [email protected]

Postal address: 2, Rue Edward Steichen, L- 2540 Luxembourg (1st floor Oksigen building)

Telephone number: +352 2033 1266

Changes to the privacy policy and your duty to inform us of changes.

We keep our privacy policy under regular review. This version was last updated on 8 December 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
 

2. WHAT INFORMATION DO WE COLLECT FROM YOU?

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, marital status, title, date of birth, language spoken, nationality and/or citizenship.

Employment Data includes name of employer or nature of your relationship with the client using our services (for example, if you are a director or shareholder of your company), and job title.

Background Check Data includes information about criminal convictions and offences, information contained in identification documents, and other relevant "know your customer" checks information (such as financial information).

Contact Data includes work and residential address, email address and telephone numbers.

Financial Data includes bank account and payment card information.

Transaction Data includes details about your incoming and outgoing payments, transactional counterparties, other relevant information pertaining to these transactions.

Technical Data includes internet protocol (IP) address, your login information, browser type and version, time zone setting, location, browser plug-in types and versions, and operating system.

Profile Data includes your username and password, your preferences, and feedback and survey responses.

Usage Data includes information about how you use our website and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

We may receive information about you if you use any of the other websites we operate or the other services we provide.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). However, we do collect information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law or to comply with our regulatory obligations (such as to carry out "know your customer" checks) or under the terms of a contract we have or are trying to enter with you, your business or employer and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, your employer or business. In this case, we may have to decline to provide or cancel the relevant service but we will notify you and/or your business or employer if this is the case at the time.
 

3. HOW DO WE COLLECT YOUR DATA?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us any of the data listed above by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • register with us;

    • subscribe to our service or publications; 

    • use our services;

    • request marketing or information about our services to be sent to you; or give us feedback or contact us for any reason.

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy https://3s.money/cookies for further details.

  • Third parties or publicly available sources. We are also working closely with third parties (including service providers, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) and may receive and exchange information about you with them (please refer to Section 5 for a more detailed description). We may also receive information about you from your employer or business in connection to an application for or use of our services. If you receive a payment from a client using our services, then they will provide your information to us to facilitate the payment.
     

4. WHAT WE DO WITH YOUR DATA?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with our legal and/or regulatory obligations.

  • In limited circumstances, with your explicit consent. Where we rely on consent, you have the right to withdraw your consent at any time by contacting us.

Purposes for which we will use your personal data.

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
 

Purpose/Activity

Type of data

Lawful basis for processing 

To register you, your business or employer as a new client for a 3S Money electronic money account (including to carry out checks)

Identity, Employment, Background Check, Contact, Financial, Profile

Performance of a contract with you

To provide our services to including: 

  • issuing electronic money to you in exchange for receiving money from you or on your behalf;

  • holding electronic money for you in your electronic money account in multiple currencies; and

  • facilitating payments to and from your electronic money account

Identity, Employment, Background Check, Contact, Financial, Profile

(a) Necessary for our legitimate interests (to enable us to provide services, and to comply with our internal policies and procedures)

(b) Performance of a contract with you (to enable you to use our services)

To contact you about our services:
if you have given us your contact information, we may use these details to get in touch with you about the services we offer such as by following up on an incomplete registration process or to email you details of offers you may be interested in.
You may opt out of this at any time by telling us, or if we have contacted you via email, you will be given an option to opt-out by clicking the relevant email link

Identity, Employment, Contact, Profile, Marketing and Communications

(a) Necessary for our legitimate interests (to develop our services and grow our business)

(b)     Your consent (where we seek your explicit consent)

To improve our services:

  • we may use your personal data to analyse how you are using the 3SM service and to gain insights into how we can improve our products and services

Identity, Employment, Contact, Financial, Transaction, Technical, Profile, Usage

Necessary for our legitimate interests (to develop our services and grow our business)

To monitor and record telephone calls for regulatory purposes, to confirm your instructions,

Identity, Employment, Contact, Transaction

(a) To comply with our legal and regulatory obligations (to monitor and record telephone calls for regulatory purposes)

To manage our relationship with you, including to provide customer support and account administration services, to investigate complaints or concerns, and to notify you about changes to our terms or privacy policy

Identity, Employment, Background Check, Contact, Financial, Transaction, Technical, Profile, Usage, Marketing and Communications

(a) Necessary for our legitimate interests (to keep our records updated, to enable us to provide services, to monitor and maintain business processes, and to protect our legal rights and interests) 

(b) To comply with our legal and regulatory obligations (to investigate complaints or concerns, and to notify you about changes to our terms or privacy policy)

To provide information about related products and services:

  • we may use your personal data to provide you with information on related products and services that you may be interested in. This information will be provided electronically, either via our website, app, or email.

We will not transfer any of your personal data to third parties for this purpose unless you give us your explicit consent.

Identity, Contact, Profile, Usage, Marketing and Communications

(a) Necessary for our legitimate interests (to enable us to grow our business)

(b) Your consent (where we seek your explicit consent)

To provide information to third parties or 3SMC Group companies for marketing and behavioural analysis purposes and for related products and services:

Contact, Profile, Marketing and Communications

Your consent (where we seek your explicit consent)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity, Background Check, Contact, Financial, Transaction, Technical, Profile, Usage

(a) Our legitimate interests (to enable us to provide our services, and to maintain the security of our business, website and systems

(b) To comply with our legal and regulatory obligations

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Identity, Contact, Profile, Usage, Marketing and Communications, Technical

Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Financial, Transaction, Technical, Profile, Usage, Marketing and Communications

Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)


Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us using the contact details above.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see 3S Money (Luxembourg) S.A. Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 

5. DISCLOSURES OF YOUR PERSONAL DATA 

In order to deliver our services and in compliance with applicable law, your personal data may also be transferred to the following third parties:

  • Other companies in the 3S Money Club Group and who are based in the UK and Singapore and provide communication, compliance, IT and system administration services and undertake analytics and reporting. 

  • Service providers that may be acting as processors based in the European Union or the United Kingdom who provide IT, system administration, identification and two-factor authentication services.

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services 

  • National, European and foreign regulators and authorities to the extent required and in compliance with applicable law. 

  • Law enforcement agencies, judicial bodies, government bodies, and tax authorities when we are under a legal obligation to do so.

  • Third-party credit reference agencies, in circumstances where we may need to assess creditworthiness and where permitted by applicable law.

  • KYC-AML partners to facilitate your onboarding as a client.

  • Our banking partners to provide you with necessary services.

  • FX brokers to provide you with forex services.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

  • Other third parties where we are permitted by law to share your personal data, it is in our legitimate interests or those of a third party, and it is not inconsistent with the purposes outlined above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

3SM has listed in this Privacy Policy the third-party service providers and business partners performing services on our behalf, to whom we may disclose your data, together with the purpose of disclosure and type of information disclosed. You will find a link to those third parties here. By accepting this Privacy Policy, you expressly agree to the transfer of your data to those third parties for the purposes listed.
 

6. INTERNATIONAL TRANSFERS 

We take the security of your data very seriously, and all of your personal data will be kept according to strict safeguards and in compliance with the  EU GDPR (as applicable) and the applicable Luxembourg law. Your data will be stored on cloud servers within the EEA and UK and we will only store or transfer your data outside the EEA or UK in the event that:

  • the jurisdiction in question has been assessed as providing an adequate level of protection for personal data; or

  • we have entered into a contract with the entity to which we transfer your personal data to ensure that it is adequately protected.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or UK.
 

7. DATA SECURITY 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 

8. HOW LONG WE WILL KEEP YOUR DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for ten years after they cease being customers for tax and documentation purposes.
In some circumstances you can ask us to delete your data: see section 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
 

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

These include the right to:

Be informed about what personal data we hold and how we are using it. This information is contained within this privacy notice.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You can do so, by making a ‘subject access request’ to us.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You may always object to further use of your data for direct marketing purposes by clicking the “unsubscribe” button within marketing emails or by contacting us by writing to us at [email protected]

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format free of charge and on request. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at 3S Money (Luxembourg) S.A. ,2, Rue Edward Steichen, L- 2540 Luxembourg (1st floor Oksigen building) ; by telephone on +352 2033 1266; or by emailing [email protected]

Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the CNPD, the National Commission for Data Protection in Luxembourg Contact details for the CNPD can be found on https://cnpd.public.lu/en.html.

No fee is usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the reasons of the delay and keep you updated.