This Privacy Policy explains how Go Zazoo Ltd ("Go Zazoo," "we," "us," or "our") and our partner FinXP Ltd ("FinXP") collect, use, store, and share your personal data when you use the Zazoo website, mobile application, and related services (collectively, the "Zazoo Services") in conjunction with FinXP's electronic money services.
Go Zazoo provides the technical platform, while FinXP is the licensed Electronic Money Institution (EMI) responsible for issuing electronic money and providing payment services. Both entities are committed to protecting your privacy and handling your personal data in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the Data Protection Act (Chapter 440 of the Laws of Malta).
Important Notice
Go Zazoo Ltd operates as a technical platform facilitating access to electronic money and payment services. Electronic money accounts and payment services are provided by FinXP Ltd (Licensed Electronic Money Institution, Company registered in Malta - Registration number: C 65783, Registered office: Ardent Business Centre 4, Oratory Street, Naxxar NXR 2505 Malta, Licensed and regulated by the Malta Financial Services Authority (MFSA)). Go Zazoo Ltd is not a bank or an Electronic Money Institution.
1. Who Is Responsible for Your Data?
Data Controllers
- Go Zazoo Ltd: As the provider of the Zazoo Services platform, Go Zazoo acts as a data processor for certain data and a data controller for data related to the operation and improvement of its platform.
- FinXP Ltd: As the licensed Electronic Money Institution, FinXP acts as the primary data controller for all personal data related to your electronic money account, payment transactions, and compliance with financial services regulations (e.g., AML/CFT).
2. What Personal Data Do We Collect?
We collect personal data that is necessary to provide you with the Zazoo Services and FinXP's services, and to comply with legal obligations. This may include:
Identity Data
- Name, surname, date of birth
- Nationality, gender
- National identification number
- Taxpayer identification number
- Passport or ID document details
Contact Data
- Email address
- Postal address
- Telephone number
Financial Data
- Payment account details
- Transaction history
- Payment instructions
- Source of funds
- AML/CFT compliance information
Technical Data
- IP address, device information
- Operating system and version
- Unique device identifier
- Mobile network information
- Location data (with permission)
3. How Do We Collect Your Personal Data?
We collect personal data from various sources:
- Directly from you: When you register for an account, use the Zazoo Services, provide identity documents, communicate with us or FinXP, or update your information.
- From your devices: Through the Zazoo mobile application and website, which may collect technical and location data.
- From third parties: Credit Bureaus (for identity verification), publicly available sources (for due diligence), and affiliates and partners including FinXP.
4. On What Legal Basis Do We Process Your Personal Data?
We and FinXP process your personal data based on the following legal grounds:
Performance of a Contract
To provide you with the Zazoo Services and FinXP's electronic money and payment services, and to fulfil our respective obligations under the Terms and Conditions.
Legal Obligation
To comply with applicable laws and regulations, including AML/CFT laws, data protection laws, and reporting obligations to regulatory authorities.
Legitimate Interests
To pursue our legitimate business interests, including protecting against legal action, detecting fraud, developing services, and ensuring security.
Consent
Where required by law, we obtain your explicit consent for specific processing activities, such as direct marketing or location data collection.
5. How Do We Use Your Personal Data?
Your personal data is used for the following purposes:
- Account Management: To set up, operate, and manage your electronic money account, including processing applications and verifying identity.
- Service Provision: To enable you to use the Zazoo Services and FinXP's services, including sending and receiving money and processing transactions.
- Compliance and Security: To comply with AML/CFT obligations, detect and prevent fraud, and ensure platform security.
- Service Improvement: To review, develop, and improve our products and services through analysis and research.
- Communication: To send you service-related communications, updates, and important notices.
- Marketing: If you have given consent, to inform you about other products and services.
- Legal and Regulatory: To respond to legal processes and enforce our Terms and Conditions.
6. Who Do We Share Your Personal Data With?
We share your personal data with:
- FinXP Ltd: As our licensed EMI partner, for providing electronic money and payment services and fulfilling regulatory obligations.
- Go Zazoo Ltd: FinXP shares relevant data with Go Zazoo to enable operation of the Zazoo Services platform.
- Affiliates and Subsidiaries: Within corporate groups for operational, analytical, and compliance purposes.
- Service Providers: Third-party vendors contractually bound to protect your data.
- Law Enforcement: Regulatory authorities and law enforcement as required by law.
- Credit Bureaus: For identity verification and credit reporting purposes.
7. International Data Transfers
Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (EEA). Where such transfers occur, we and FinXP ensure that appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission.
8. Data Retention
We and FinXP retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including AML/CFT obligations, which typically require retention for a minimum of five years after the termination of the business relationship.
9. Your Data Protection Rights
Under GDPR, you have the following rights regarding your personal data:
Access Rights
- Right to Access: Request a copy of your personal data
- Right to Rectification: Correct inaccurate or incomplete data
Control Rights
- Right to Erasure: Request deletion under certain circumstances
- Right to Restriction: Limit processing under certain conditions
Transfer Rights
- Right to Data Portability: Receive data in structured format
- Right to Object: Object to processing based on legitimate interests
Consent Rights
- Right to Withdraw Consent: Withdraw consent where applicable
To exercise any of these rights, please contact FinXP's Customer Service Centre at support@finxp.com.
10. Security Measures
We and FinXP are committed to keeping your personal data secure. We implement and maintain appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, including against accidental loss, destruction, storage, or access.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the updated policy on our website or through other appropriate communication channels.
12. Company Information
Go Zazoo Ltd (Trading name: Zazoo)
Zazoo modern payments and GoZazoo are copyright of Go Zazoo Ltd
Company registered in Cyprus - Registration number: HE 461195
Registered office: Alexandreias, 2-4, BRIDGE TOWER, Flat/Office 3A, 3013, Limassol, Cyprus
FinXP Ltd (Licensed Electronic Money Institution)
Company registered in Malta - Registration number: C 65783
Registered office: Ardent Business Centre 4, Oratory Street, Naxxar NXR 2505 Malta
Licensed and regulated by the Malta Financial Services Authority (MFSA)
MFSA Address: Triq l-Imdina, Zone 1, Central Business District, Birkirkara, CBD 1010, Malta
Website: www.finxp.com
Contact: Telephone: +356 2792 2864, Facsimile: +356 2124 0385
Email: support@finxp.com
13. Contact Us
If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact FinXP's Data Protection Officer at:
FinXP Ltd
Ardent Business Centre 4, Oratory Street, Naxxar NXR 2505, Malta
Email: support@finxp.com
14. Complaints
If you are not satisfied with how your data has been handled, you have the right to lodge a complaint with the relevant supervisory authority:
For FinXP (Malta)
Information and Data Protection Commissioner (IDPC)
Level 2, Airways House, High Street, Sliema SLM 1549, Malta
Email: idpc.info@idpc.org.mt
Website: www.idpc.org.mt