This policy (together with our Terms & Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand the types of information we collect from you, how we use that information and the circumstances under which we will share it with third parties.
- By using LuLu Money mobile application (“App” or “Mobile App”) or visiting our website (our “Website”) you are accepting and consenting to the practices described in this policy.
- Unless context otherwise requires a reference to the Website, it shall be deemed to also refer to the App.
- For the purpose of the relevant data protection legislation, the data controller is LuLu International Exchange authorised by the regulatory authority to carry out the business of remittances and is bound to fulfill the regulations and licensing conditions of the regulatory authority.
4. What type of information do we collect from you?
We may collect and process the following data about you:
- Information you give us: You may give us information about yourself by filling in forms, providing your ID images on our Mobile App or by corresponding with us by phone, e-mail or otherwise.
- This includes (but is not limited to) information you provide when you register to use our Mobile App, transfer money using our Mobile App and when you report a problem with our App.
- The information you give us may include your name, date of birth, address, e-mail address and phone number, financial and payment tokens, payment reason, personal description, geographic location, photograph, any government ID and copies of identification, address proof and other documents.
- Information we collect about you: with regard to each of your visits to our Mobile app/Website, we may automatically collect the following information:
- Details of the money transfers you carry out via our mobile app, including the geographic location from which the transaction originates;
- Technical information, including the Internet protocol (IP) address used to connect your computer / phone / any other device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; your physical location via GPS, your location as identified by your mobile operator and
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); what you viewed or searched for; page response times, download errors, cookie based information, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number or our representatives at any time.
- Information we receive from other sources:
- We may receive information about you if you use any of the other websites we operate or the other services we provide either directly or through our affiliates.
- We also may receive information from the banks and other financial institutions you are using to transfer money to us or using as a means of identity verification.
- We are also 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) and may receive information about you from them.
5. How do we use the information collected from you?
- We will use this information you give to us:
- To carry out our obligations arising from any contracts entered into between you and us (including the Customer Agreement) and to provide you with the information, products and services that you request from us; to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
- To provide you with information about services we feel may interest you;
- To notify you about changes to our service;
- To ensure that content from our Website is presented in the most effective manner for you and for your computer or mobile device; and
- To comply with legal and regulatory requirements
- Information we collect about you. We will use this information:
- To administer our App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our App to ensure that content is presented in the most effective manner for you and for your computer or mobile device;
- To allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our App safe and secure;
- To comply with regulatory, Know Your Customer (KYC) requirements and Anti Money Laundering (AML) requirements as may be required under local laws and global treaties/ jurisdictions;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
- To make suggestions and recommendations to you and other users of our App about goods or services that may interest you or them.
- Information we receive from other sources: We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
6. Disclosure of Collected Information
- We shall take appropriate measures to protect your information and shall restrict this information to only those personnel who are bound to discharge their duties for effecting the payment. Any information shared with third parties. e.g: Business partners, suppliers and subcontractors if any, shall be subjected to non disclosure contractual requirements.
- We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
- We may share your information with selected third parties including:
- Business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you;
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; and
- Analytics and search engine providers that assist us in the improvement and optimisation of our App;
- The sharing of such data would be restricted to sharing of the minimum information required for such purpose and we would not be sharing any personally identifiable information with such providers at any time.
- We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If LuLu Money or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers 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 in order to enforce or apply the Customer Agreement and any other documents referred to on it; or to protect the rights, property, or safety of LuLu Money, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
- We may also show your first name, first initial of your surname and photograph to the recipient of your money transfer, to your peer-to-peer counterparty and disclose these on the transfer map on our webpage to show some recent transfers done through LuLu Money as an example.
7. Storage of Personal Data
- The data that we collect from you may be transferred to, and stored at, a destination outside the local geography.
- It may also be processed by staff operating outside the local geography who work for us or for one of our suppliers.
- Such staff maybe engaged in, among other things, the fulfilment of your money transfer, the processing of your payment details and the provision of support services.
- By submitting your personal data, you agree to this transfer, storing or processing.
- All information you provide to us is stored on our secure servers.
- Any payment transactions will be encrypted using Transport Layer Security (TLS).
- Where we have given you (or where you have chosen) a password or PIN which enables you to access certain parts of our App, you are responsible for keeping this password or PIN confidential.
- We ask you not to share your password and PIN with anyone at any time, including any representative who is or claims to be authorized by LuLu Money.
- We will do our best to protect the data that is shared via the internet..
- Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.
- We restrict access of your personal information to those employees of LuLu Money who have a business reason for knowing such information.
- We continuously educate and train our employees about the importance of confidentiality and privacy of customer information.
- We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from any unauthorised access.
- We would not directly sell any or all of your data to a third party where such use of data is not required for the purpose of providing LuLu Money services or offers.
- We may choose to provide aggregated information that represents trends, group behaviour or patterns which does not include any personally identifiable information, to third parties for marketing and research purposes.
- You have the right to ask us not to process your personal data for marketing purposes by contacting firstname.lastname@example.org.
- Our App may, from time to time, contain links to and from the Apps of our partner networks, advertisers and affiliates.
- If you follow a link to any of these Apps, please note that these Apps have their own privacy policies and that we do not accept any responsibility or liability for these policies.
- Please check these policies before you submit any personal data to these Apps.
9. Access of Information
- Depending on applicable laws, you may have the right to access information held about you.
- Your right of access can be exercised in accordance with the relevant data protection legislation.
- Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.
10. AML/CFT and Sanctions Policy.
AML/CFT policy will be the same as the policy of the service provider in the country.
You agree that we have the right to block, refuse or delay the process of your transactions without any claim or liability on our part or its officers if we suspect that the transactions you execute breach the regulatory authority of the country’s AML laws and regulations or the laws and regulations of any other country or jurisdiction.
• If it involves any natural person or entity (Corporate or Governmental) who has been sanctioned or is directly or indirectly connected to any person that is sanctioned by OFAC, United Nations, the country of operation or any other country.
• If you are directly or indirectly involved in any proceeds, purpose or any lawful conduct related to Anti Money Laundering and The Financing of Terrorism.
You will provide us with the requested information or any evidence required which we shall obtain from you to manage our Anti Money Laundering and Combating the Financing of Terrorism and Sanction Risks or obligation to comply with the applicable laws and regulations in the country of operation or any other country.
You agree that we have the right to disclose any information pertaining to the person or payment instructions to any law enforcement agency, the regulatory authority or a court where required by any law, order, decree or regulation in the country of operation or any other country or Jurisdiction. We shall also have the right to share this information to our correspondent or agents through whom we process your payment for the purpose of Compliance with any such law, regulations, order or decree.
You confirm that you are solely acting on behalf of yourself and not acting on behalf of any other third party and you warrant that you will disclose to us in advance if you are acting on behalf of another person or third party. We shall have the right to request you to provide us with any additional documentation as required by law if you are acting on behalf of any another party. We are required to receive and review such documentation and shall also require the other (third) party to agree with the terms and conditions of this service in order to comply with the AML/ CFT laws and regulations and also to ensure our compliance with the applicable laws and regulations applicable to us in the country of operation.
You agree and declare that any information we process for your transactions according to your transactions or on behalf of you shall not breach any laws and regulations of country of operation or any other country.
11. Policy Updation
We reserve the right to change or update this policy at any time by placing a prominent notice on LuLu Money’s website. Such changes shall be effective immediately upon posting to this website.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will take all efforts to notify you regarding the updates. We may notify you here, or by means of a notice on our homepage.