Privacy Policy

 

Welcome!

Move 78 provides economic infrastructure for the internet. Businesses of all sizes use our software and services to accept payments and manage their businesses online. Move 78 cares about the security and privacy of the personal data that is entrusted to us.

This policy describes the Personal Data that we collect, how we use and share it, your rights and choices, and how you can contact us about our privacy practices.

Move 78 (“Move 78”, “we”, “our” or “us”) provides its services globally and the Move 78 entity responsible for the collection and use of personal data under this Privacy Policy differs depending on your country.

We may collect and use personal data when we do business with you or when you do business with those that use our services. Some of our services may be accessed directly by you, including through our websites that reference this policy (e.g. Move 78.com) (collectively “Sites”). Many of our services are provided to others in connection with their own business and activities, and you may engage with Move 78 services as part of another’s service, such as when you make a payment to a merchant and we provide the payment processing services to that merchant through Move 78 Checkout (collectively, we refer to Sites and direct and indirect services as “Services”). This policy applies to Move 78’s own Services. Websites, products and services of third-parties and some affiliates of Move 78 are subject to their own separate privacy policies.

This Privacy Policy includes important information about your Personal Data and we encourage you to read it carefully. You can also use these links to jump to a specific section.

 

1. Overview

Move 78 obtains Personal Data about you from various sources. “You” may be a visitor to one of our Sites (“Visitor”), a user of one or more of our Services (“User” or “Move 78 User”), or a direct or indirect customer of a User (“Customer”). If you are a Customer, your agreement with the relevant Move 78 User should explain how the Move 78 User shares your Personal Data with Move 78. If you have questions about this sharing, then you should direct those questions to the Move 78 User.

 

2. Personal Data We Collect

a. Personal Data that we collect about you

Personal Data is any information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. device information, IP Address). In many cases, the Personal Data that you provide directly to us through our Services will be apparent from the context in which you provide the data:

In connection with fraud monitoring, prevention, detection, and compliance activities for Move 78 and its Users, we receive identity related from the following sources:

This Personal Data (e.g., name, address, phone number, country) helps us to confirm identities and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by a Customer with a Move 78 User.

You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details in connection with trade shows or other events.

b. Information that we collect automatically on our Sites and through marketing of our products

Our Sites use cookies and other technologies. These technologies record information about you, including:

 

3. How We Use Personal Data

a. Our Services

We rely upon a number of legal grounds to enable our use of your Personal Data. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete transactions and to provide payment-related services to our Users.

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Contractual and pre-contractual business relationships

We use Personal Data for the purpose of entering into business relationships with prospective Move 78 Users, and to perform the contractual obligations under the contracts that we have with Move 78 Users. Activities include:

Legal compliance

We use Personal Data to verify the identity of our Users in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as AML (Anti-Money Laundering) and KYC (Know-Your-Customer) obligations, and financial reporting obligations. For example, we may be required to record and verify a User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits.

Legitimate business interests

Where allowed under applicable law, we rely on our legitimate business interests to process Personal Data about you. When we do so, we balance our legitimate interests against the interests and rights of the individuals whose Personal Data we process. The following list sets out the business purposes that we have identified as legitimate:

Payment transactions and related services (Move 78 as a data processor)

We use Personal Data of Customers to provide our Services to Users, including to process online payment transactions and authenticate Customers on behalf of our Users. . All such use is pursuant to the terms of our business relationships with our Users. In addition, we may offer payment-related services to Users who have requested such services, and our delivery of such related services to our Users may involve the use of Personal Data. For example, a Move 78 User may specify parameters for transactions submitted by its Customers that determine whether the transactions are blocked or allowed by our payment processing Services. In such cases, the User is responsible for the collection and use of Customer’s Personal Data for the payment transactions and payment-related services. We also use Personal Data to detect and prevent fraud. In providing such services, we may provide Users who have requested such services Personal Data from a Customer to assess the fraud risk associated with an attempted transaction by their Customer.

b. Marketing and events-related communications

We may send you email marketing communications about Move 78 products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with applicable law, including any consent requirements. For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.

c. Advertising

When you visit our Sites, we (and our service providers) may use Personal Data collected from you and your device to target advertisements for Move 78 Services to you on our Sites and other sites you visit (“interest-based advertising”), where allowed by applicable law, including any consent requirements. For example, when you visit our Site, we will use cookies to identify your device and direct ads for our Services to you. You have choices and control over our cookies (or similar technologies) we use to advertise to you. 

 

4. How We Disclose Personal Data

Move 78 does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.

a. Move 78

We share Personal Data with other Move 78 affiliated entities in order to provide our Services and for our administration purposes.

b. Service providers

We share Personal Data with certain of our service providers subject to contract terms that limit their use of Personal Data. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, marketing service, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America. .

c. Business partners

We share Personal Data with third party business partners in connection with our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment method providers (such as credit card networks) when we provide payment processing services, and the professional services firms that we partner with to deliver Move 78 Atlas.  about what Move 78 does with other third parties.

d. Our Users and third parties authorized by our Users

We share Personal Data with Users to maintain a User account and provide the Services and third party services. We share data with parties directly authorized by a User to receive Personal Data. This includes sharing Personal Data of Customers with Users to assess the fraud risk associated with attempted transactions by Customers, or when a User authorizes a third party application provider to access the User’s Move 78 account using Move 78 Connect. The use of Personal Data by an authorized third party is subject to the third party’s privacy policy.

e. Corporate transactions

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Privacy Policy.

f. Compliance and harm prevention

We share Personal Data as we believe necessary: (i) to comply with applicable law, or rules imposed by payment method in connection with use of that payment method; (ii) to enforce our contractual rights; (iii) to protect the Services, rights, privacy, safety and property of Move 78, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

5. Your Rights and Choices

You may have choices regarding our collection, use and disclosure of your Personal Data:

a. Opting out of receiving electronic communications from us

If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you other messages in connection with providing our Services.

b. How you can see or change your account Personal Data

If you would like to review, correct, or update Personal Data that you have previously disclosed to us, you may do so by signing in to your Move 78 

c. Your data protection rights

Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:

d. Process for exercising data protection rights

We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may have the right under applicable laws to consult with the data protection authority in your country.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

If you are a Customer of a Move 78 User, please direct your requests directly to the User. For example, if you are making, or have made, a purchase from a merchant using Move 78 as a payment processor, and you have a request that is related to the payment information that you provided as part of the purchase transaction, then you should address your request directly to the merchant.

6. Security and Retention

We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Privacy Policy against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (e.g., you feel that the security of your account has been compromised), please contact us immediately.

We retain your Personal Data as long as we are providing the Services to you or our Users (as applicable). Even after we stop providing Services directly or indirectly to you, and even if you close your Move 78 account or complete a transaction with a Move 78 User, we keep your Personal Data in order to comply with our legal and regulatory obligations. We may also keep it to assist with our fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In all cases where we keep data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

7. International Data Transfers

We are a global business. Personal Data may be stored and processed in any country where we do business or our service providers do business. We may transfer your Personal Data to countries other than your own country, including to the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. Officials (such as law enforcement or security authorities) in those other countries may be entitled to access your Personal Data.

8. Use by Minors

The Services are not directed to minors, including children under the age of 13, and we request that they not provide Personal Data through the Services. In some countries, we may impose higher age limits as required by applicable law. We do not sell any Personal Data of Customers, Visitors or Users, including those aged between 13 to 16.

9. Updates To this Privacy Policy and Notifications

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services.

We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through your Move 78 Dashboard, email address and/or the physical address listed in your Move 78 account.

If applicable law requires that we obtain your consent or provide notice in a specified manner prior to making any changes to this Privacy Policy applicable to you, we will provide such required notice and will obtain your required consent.

10. Links To Other Online Services

The Services may provide the ability to connect to other online services. These online services may operate independently from us and/or may have their own privacy notices or policies, which we strongly suggest you review. If any online service linked to our Services is not owned or controlled by us, or does not claim to be covered by this Privacy Policy, we are not responsible for it and/or it is not covered by this Privacy Policy. Please refer to the privacy policy associated with that online service.

11. Controllers and Jurisdiction-specific Provisions

Depending on the activity, Move 78 acts as a Controller and Processor. . For more information on the Move 78 entity that is responsible under this Privacy Policy. .

Australia

United States - California

If you are a consumer located in California, we process your personal data in accordance with the California Consumer Privacy Act (CCPA). This section provides additional details about the personal information we collect and use for purposes of CCPA.

a. How We Collect, Use, and Disclose your Personal Information

 

b. Your CCPA Rights and Choices

As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

To submit a request to exercise any of the rights described above, contact our DPO.

ALL

When exercising your rights, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required. If you are a Customer of a Move 78 User, please direct your requests directly to the Move 78 User with whom you shared your personal information.

12. Contact Us

If you have any questions or complaints about this Privacy Policy, please contact us