PRIVACY POLICY

Last updated November 2023

This privacy notice for GloRep  (’we’ ’us’, or ’our’) describes how and why we might collect, store, use and/or share (’process’) your information when you use our services (’Services’), such as when you:

  • – Visit our website at https://www.glorep.com, or any website of ours that links to this privacy notice
  • – Download and use our mobile application (GloRep), or any other application of ours that links to this privacy notice
  • – Engage with us in other related ways, including any sales, marketing, or events


Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at co********@gl****.com



  1. 1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short : We collect personal information that you provide to us.


We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. When you communicate with us by email, telephone, chat or any another method, we may collect the communication and any personal information you share


Personal information Provided by You

The information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:


Personal Identification such as your full name, date of birth, nationality, cell phone number, email address, country of residence (and/or proof of residence), employment status, and/or national identification number for the purpose of assigning a unique identifier to you.


Biometric information such as the selfie/video and/or liveness test you provide to us when creating your GloRep account, video/audio recording, or other evidence of yourself with identification documentation.


National identification documentation such as your drivers licence, passport, national identification documents, as well as any other information deemed essential to meet our legal requirements under financial or anti-money laundering legislation.


Administrative and financial information such as bank account information, including your source of funds, credit and/or debit card details, transaction history, tax records, or any evidence of your income or net worth.


Transaction information such as your GloRep account’s transaction data and data on the recipient of any transaction(s), currency preferences, payment methods, and date or timestamps.


Correspondence-related information such as details shared with us through customer support and/or survey reply interactions such as email addresses, phone numbers and information provided to us that implicitly or explicitly of a confidential or private nature.


Information legitimately acquired from third parties, such as credit information, online identifiers for fraud prevention, information about alleged criminal conduct, sanctions data, blockchain data, or other personal data about you that has been submitted by a service provider. Public databases or affiliates such as transaction and product use information, information obtained from public databases, information from marketing, advertising or information analytics providers.


All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.


Information automatically collected.

In Short : Some information, such as your Internet Protocol (IP) address/es and/or browser and device characteristics, is collected automatically when you visit our Services.


We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.


Like many businesses, we also collect information through cookies or similar technologies. You can find out more about this in our Cookie Policy: https://glorep.com/cookiepolicy


The information we collect includes:

Log and Usage Data for service-related, diagnostic usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP Address, device information, browser type, and settings and information about your activity in the Services (such as date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports, sometimes called ‘’crash dumps’’, and hardware settings).


Location Data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data and tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting in your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services


  1. 2. HOW DO WE PROCESS YOUR INFORMATION?

Personal information you disclose to us

In Short : We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.


We process your personal information for a variety of reasons, depending on how you interact with our Services, including:


To facilitate account creation and authentication and otherwise manage user account. We may process your information so you can create and log in to your account, as well as keep your account in working order.


To send you marketing and promotional communications. We may process the personal information you need to send us for our marketing purposes, If this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see ‘’WHAT ARE YOUR PRIVACY RIGHTS?’’ below.


To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.


To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we ca improve them


To save or protect an individuals vital interest. We may process your information when necessary to save or protect and individuals vital interest such as to prevent harm.


  1. 3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

Personal information you disclose to us

In Short : We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.


If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:


Consent. We may process your information if you have given us permission (i.e. consent) to use your personal for a specific purpose. You can withdraw your consent at any time.


Legitimate Interests. We may process your information when we believe it is reasonable necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

  • – Send users information about special offers and discounts on our products and services
  • – Analyse how our Services are used so we can improve them to engage and retain users
  • – Diagnose problems and/or prevent fraudulent activities


Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved


Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person


If you are located in Canada, this section applies to you.

We may process your information if you have given us specific information (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.


In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • – If collection if clearly in the interests of an individual and consent cannot be obtained in a timely way
  • – For investigations and fraud detection and prevention
  • – For business transactions provided certain conditions are met
  • – If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • – For identifying injured, ill, or deceased persons and communicating with next of kin
  • – If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • – If it is reasonable to expect collection and use with consent would compromise the availability of the accuracy of the information and the collection is         reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • – If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • – If it was produced by an individual in the course of their employment, business or profession and the collection is consistent with the purposes for which the   information was produced
  • – If the information is publicly available and is specified by the regulations

  1. 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short : We may share information in specific situations described in this section and/or with the following third parties.


We may need to share your personal information with the following:

  • – Any organisation that processes payments you have authorised, offers you support, or in any other way offers you our goods and services.
  • – Any employee of ours
  • – Banking institutions and other organisations with which we collaborate in order to deliver our services and to process payments you have authorised
  • – Third party service providers for identity verification.
  • – Businesses and organisations that offer us services, such as those related to technological infrastructure, marketing and analytics, and the creation of websites and mobile applications
  • – Businesses and groups that help us with identification checking, background checks, and due diligence. We utilise GloRep to check if the selfie you take while creating your GloRep account corresponds to the picture of you on your Identification Card, as well as utilise their services to run a facial similarity test (liveness check), which compares your image against a video that you submit. Biometric information may be among the data gathered from your submissions. You acknowledge that you have read, understood and accepted the GloRep Facial Scan Policy, Privacy Policy, and Terms of Service by creating an account with GloRep
  • – Our Professional advisors and business partners

Besides the above exceptions, we shall regard your personal information as private and confidential and will not divulge it to any other parties except:

  • – When we have your consent to do so
  • – In situations where we deem it reasonably necessary to do so in order to satisfy any law, rule, regulation, legal process, or government request (such as when it comes to meeting tax and AML reporting requirements or responding to requests from law enforcement), to enforce our Terms of Use or other agreements, or to defend the rights, property, or safety of us, our clients, or others

 

  1. 5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short : We may use cookies and other tracking technologies to collect and store your information.


We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies is set out in our Cookie Notice: https://glorep.com/cookiepolicy. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies, however, if you select this setting you may be unable to access certain parts of our site.

 

  1. 6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short : We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.


We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as compliance with our legal obligations, preventing fraud, resolving disputes, tax, accounting, or other legal requirements, including AML/KYC compliance or other financial regulatory obligations).

Our third party service providers may also retain your personal information according to their respective retention policies.


  1. 7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short : We aim to protect your personal information through a system of organisational and technical security measures.


Your privacy is very important to us and we are committed to protecting your personal information from unauthorised access or use. We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our services is at your own risk. You should only access the Services within a secure environment. GloRep will address any Data Breaches in accordance with applicable data protection laws.


  1. 8. DO WE COLLECT INFORMATION FROM MINORS?

In Short : We do not knowingly collect data from or market to children under 18 years of age.


We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependant’s use of the Services and as such provide consent to this Privacy Policy. If you are under the age of 18 and have not obtained the consent of your legal guardian, please do not provide any personal information through our website or services.


  1. 9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short : You may have rights regarding the processing of your personal information, depending on the data protection laws that apply to you.


The majority of the information GloRep gathers and the way in which we use it are essential for us to deliver and enhance the Services we offer to you or to fulfil our legal duties. You may have the following rights regarding the processing of your personal information, depending on the data protection laws that apply to you. If any of the following rights are not provided under applicable data protection laws in your jurisdiction, GloRep has complete discretion in providing such rights to you.

You may have various rights in relation to your personal data, depending on the nation or state in which you reside, including the ability to :

  • – Request a copy of the personal information we store about you
  • – Request a transfer of your personal data in a structured, generally accepted, and machine-readable format to you or a third party of your choice
  • – Object to the use of your personal information for any purpose, including marketing;
  • – Choose not to allow us to share you personal information with our affiliates or other parties for their marketing efforts or for purposes other than those   specified in this policy
  • – Request that we update, remove, or limit how we use your personal information.


If you would like to exercise any of the rights listed above, you are allowed to do so without facing discrimination, kindly open a support ticket. GloRep may take steps to verify your identity before complying with any of your requests to exercise your rights listed below in order to protect your privacy and security. We may decline your request or request additional verification information if we are unable to verify your identity.


  1. 10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.


  1. 11. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

As GloRep is a global organisation, your personal information may be moved to, stored, and processed outside of the country in which you currently reside. As a result, the laws of those other countries may be different from the ones that apply in your own. One or more locations outside the European Economic Area (EEA) may receive, store, and handle data that was collected there. You hereby expressly consent to the transfer, storing, or processing of your personal data outside of your jurisdiction by accepting this Privacy Policy and providing your personal data.


  1. 12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short : You may have additional rights based on the country you reside in.


Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘’How can you review, update, or delete the data we collect from you?’’


If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator the details of which are:


The Information Regulator (South Africa)

General enquiries : en*******@in***********.za

Complaints (complete POPIA/PAIA form5)

PA************@in***********.za & PO*************@in***********.za

 

  1. 13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short : Yes, we will update this notice as necessary to stay compliant with relevant laws.


We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. We will do our best to notify you of any significant changes to the privacy notice in the most efficient way, such as posting a notice on our website or application, emailing the address connected to your GloRep account, or both. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information. Accessing and/or use of the Services after the Effective Date will signify that you have read, understood, accepted, and agreed to be bound by this privacy notice in your individual capacity


  1. 14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), GloRep representative, by email at su*****@gl****.com, by phone at 0872651743, or contact us by post:

GloRep (Pty) Ltd

GloRep Representative

Blueberry Office Park, Block D, Unit 25

23 Apple Street, Honeydew

Randburg, Gauteng 2170

South Africa

 

  1. 15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.