Version: effective on 15 July 2019
and/or of our mobile application (the “Mobile App”). The terms “we,” “us,” and “our” refer to Instamo and its licensed partner and its affiliates. When we ask for certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes. Any non-required information you provide to us is done so voluntarily. You decided whether to provide us with these non-required information; you may not be able to access or utilize all of our Services if you choose not to.
We want you to understand the types of information we collect when you register for and use Instamo’s services.
Information you provide to us at registration.
When you create a Instamo Account, you provide us with personal information that includes your contact information (Email Address, phone number, name, and a password).
This also includes information you provide through your continued use of our Services, participate in discussion boards or other social media functions on our Website or App, enter a competition, promotion or survey, and when you report a problem with our Services. The information you give us may include your name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), payment reason, geographical location, social security number, ID number, personal description and photograph.
Information we collect when authenticating user identity
To comply with global industry regulatory standards including Anti-Money Laundering (AML), Know-Your-Customer (KYC), and Counter Terrorist Financing (CTF), Hawking Instamo requires user accounts to undergo user identity authentication for both Personal & Enterprise-level accounts. This entails collecting formal identification.
Information we collect as you use our services
We may also need additional commercial and/or identification information from your e.g. if you send or receive certain high-value or high volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.
Service Usage Information
Through your use of the Instamo platform, we also monitor and collect tracking information related to usage such as access date & time, device identification, operating system, browser type and IP address. This information may be directly obtained by Instamo or through third party services. This service usage data helps us our systems to ensure that our interface is accessible for users across all platforms and can aid during criminal investigations.
For all personal and enterprise user accounts, we collect transaction information including deposit snapshots, account balances, transaction history, withdrawals, and other activities conducted via Instamo platform. This transaction data is monitored for suspicious trading activity for user fraud protection, and legal case resolution.
Information we collect about you. With regard to your use of our Services we may automatically collect the following information:
(a) details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;
(b) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
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. We are also working closely with third parties and may receive information about you from them.
- The banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;
- Business partners may provide us with your name and address, as well as financial information, such as card payment information;
- Advertising networks, analytics providers and search information providers may provide us with pseudonymised information about you, such as confirming how you found our website;
- Credit reference agencies do not provide us with any personal information about yourself, but may be used to corroborate the information you have provided to us.
We use your information in the following ways:
(a) to carry out our obligations relating to your contract with us and to provide you with the information, products and services;
(b) to comply with any applicable legal and/or regulatory requirements;
(c) to notify you about changes to our Services;
(d) as part of our efforts to keep our Services safe and secure;
(e). to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(f) to improve our Services and to ensure that they are presented in the most effective manner;
(g) to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
(h) to allow you to participate in interactive features of our Services, when you choose to do so;
(i) to provide you with information about other similar goods and services we offer;
(j) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; or
(k) to combine information we receive from other sources with the 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).
To provide and maintain our services
We use the information collected to deliver our services and verify user identity.
We use the IP address and unique identifiers stored in your device’s cookies to help us authenticate your identity and provide our service. Given our legal obligations and system requirements, we cannot provide you with services without data like identification, contact information and transaction-related information.
To protect our users
We use the information collected to protect our platform, users’ accounts and archives.
We use IP addresses and cookie data to protect against automated abuse such as spam, phishing and Distributed Denial of Service (DDoS) attacks.
We analyze trading activity with the goal of detecting suspicious behavior early to prevent potential fraud and loss of funds to bad actors.
To comply with legal and regulatory requirements
Respect for the privacy and security of data you store with Instamo informs our approach to complying with regulations, governmental requests and user-generated inquiries. We will not disclose or provide any personal information to third party sources without review from our legal case team and/or prior consent from the user.
To measure site performance
We actively measure and analyze data to understand how our services are used. This review activity is conducted by our operations team to continually improve our platform’s performance and to resolve issues with the user experience.
We continuously monitor our systems’ activity information and communications with users to look for and quickly fix problems.
To communicate with you
We use personal information collected, like an email address to interact with users directly when providing customer support on a ticket or to keep you informed on log ins, transactions, and security.
Instamo has implemented a number of security measures to ensure that your information is not lost, abused, or altered. Our data security measures include, but are not limited to: Secured Sockets Layered encryption technology, pseudonymisation, internal data access restrictions, and strict physical access controls to buildings & files. Please note that it is impossible to guarantee 100% secure transmission of data over the Internet nor method of electronic storage. As such, we request that you understand the responsibility to independently take safety precautions to protect your own personal information.
If you suspect that your personal information has been compromised, especially account and/or password information, please lock your account and contact Hawking Instamo customer service immediately.
We may share your information with selected third parties including:
(a) affiliates, business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you;
(b) advertisers and advertising networks solely to select and serve relevant adverts to you and others; and
(c) analytics and search engine providers that assist us in the improvement and optimisation of our site; and
(d) our money transfer partners/ subsidiaries listed in terms of service agreement.
We may disclose your personal information to third parties:
(d) 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;
(e) 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 our terms of service and other applicable agreements; or to protect the rights, property, or safety of Hawkin Instamo, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
(f) to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
(g) to prevent and detect fraud or crime;
(h) in response to a subpoena, warrant, court order, or as otherwise required by law;
(i) to assess financial and insurance risks;
(j) to recover debt or in relation to your insolvency; and
(k) to develop customer relationships, services and systems.
We do not have a published list of all of the third parties with whom we share your data with, as this would be heavily dependant on your specific use of our Services. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to You, you can request this by writing to firstname.lastname@example.org.
In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties outlined in section 5.1 that are based outside of the Amazon Web Services. In these cases, we ensure that both ourselves and our partners 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.
We may use some instances of your data in order to customise our Services and the information we provide to you, and to address your needs - such as your country of address and transaction history. For example, if you frequently send funds from one particular currency to another, we may use this information to inform you of new product updates or features that may be useful for you. When we do this, we take all necessary measures to ensure that your privacy and security are protected - and we only use pseudonymised data where ever possible. This activity has no legal effect on you.
As part of being 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. For example, so that we can provide you with a fast and efficient service, we may use ADM to verify your identity documents, or to confirm the accuracy of the information you have provided to us. None of our ADM processes have a legal effect on you.
As a marketplace to connect you with different regulated financial institutions and regulated money transfer operators, Instamo and its partners are required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.
We will always delete data that is not longer required by a relevant law or jurisdiction in which we operate.
You have the right to ask us not to contact you for marketing purposes by contacting us at email@example.com.
You have the right to correct any personal information We hold on you that is inaccurate, incorrect, or out of date.
You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which TransferWise is subject to.
You have the right to transfer your personal data between data controllers, for example, to move your account details from one online platform to another.
Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
Subject to applicable laws, you may have the right to access information we held about you. Your right of access can be exercised in accordance with the relevant data protection legislation.